ISO 14001 IN GERMANY - Umweltbundesamt · overview of ISO 14001 practice in German industry. The...

Kontinuierliche VerbesserungKontinuierliche VerbesserungKontinuierliche Verbesserunge VerbesserungContinual Improvement

Planning

Implementation and operation

Checking and corrective action

Management review

Environmental policy

ISO 14001 IN GERMANYA SURVEY OF GERMAN EXPERIENCE

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Practising environmental protection in industry means more than

complying with regulatory duties. Many companies go beyond the

statutory requirements and reduce environmental impacts through

their voluntary introduction of an environmental management sys-

tem. Such systems also yield measurable benefits for these com-

panies. Internal auditing makes it possible to identify critical

points, minimize liability risks and gain savings in resource con-

sumption and in wastewater and waste management. This can re-

sult in a sustained improvement of the environmental situation.

One tool for establishing environmental management systems is –

besides the European Eco-Management and Audit Scheme (EMAS)

– the international ISO 14001 standard adopted in 1996. The

process of revising this environmental management system stan-

dard was initiated recently and shall be concluded in the year

2004 at the latest. The goal of this revision is to achieve improved

readability of the standard and to clarify problems of understand-

ing that may arise from unclear wording. With some 2,400 certi-

fied companies, Germany is presently one of the main participat-

ing countries in this system and thus takes a leading position

worldwide. While a national survey of the application of the EMAS

Regulation adopted in 1993 is already available (Umweltbunde-

samt 1999), there has been a lack of a corresponding overview of

the application of the ISO 14001 system and the needs and wish-

es of ISO 14001 participants in Germany.

The aim of the present study is to close this gap. It illustrates in

detail the results of a research project of the German Environment

Ministry building upon the experience gained by German compa-

nies with this standard; it also presents their views and wishes. The

study is the first comprehensive survey of ISO 14001 participants

in Germany. It provides an empirically sound, representative

Foreword

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overview of ISO 14001 practice in German industry. The diverse

findings of this study, reflected notably in the recommendations

identified by the survey and reported in summarized form, are in-

tended to make a contribution to the ISO 14001 revision process.

A notable example of such input is the envisaged clarification that

the standard aims not only to improve the environmental manage-

ment system, but moreover to continuously improve environmental

performance and assure compliance with environmental law.

German interests in ISO/TC 207 are represented by the Standard-

ization Committee for Basic Principles of Environmental Protection

(Normenausschuss Grundlagen des Umweltschutzes, NAGUS) of

the German Institute for Standardization (Deutsches Institut für

Normung, DIN). The German Environment Ministry supports these

activities and the ISO/TC 207 initiative to revise ISO 14001 and is

firmly committed to a high quality of these international environ-

mental management systems.

I owe a debt of gratitude to all those involved in preparing this

study – particularly to the companies surveyed, without whose great

willingness to provide information on many issues of corporate en-

vironmental performance this study would not have been possible.

Jürgen Trittin

German Minister for the Environment, Nature Conservation and

Nuclear Safety

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Contents

ISO 14001 in Germany

II. The survey

II.1 Context

II.1.1 The environmental management

standard ISO 14001

II.1.2 Planned revision

II.2 Goal and organization of the survey

II.2.1 Goal

II.2.2 ISO TC 207 terms of reference

II.2.3 Target groups

II.2.4 Issues and questions

II.3 Survey coverage

II.3.1 Certified organizations

II.3.2 Certifiers

II.3.3 Other interested parties

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Page 12

Page 13

Page 17

Page 25

I. Summary and overview

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IV. Conclusions

IV.1 Considerations and

recommendations for a

German position

IV.1.1 General considerations

IV.1.2 Concrete recommendations

V. Lists and imprint

V.1 Lists

- References

- Figures

- Internet addresses

- The ISO 14000ff series

V.2 Imprint

III. Survey results

III.1 Current situation

III.1.1 Structural data of organizations and

individuals surveyed

- Certified organizations

- Certifiers

III.1.2 Reasons for using ISO 14001

III.1.3 Benefits expected by users

III.1.4 Resource allocation and costs

III.2 Current problems

III.2.1 General difficulties

III.2.2 Nonconformance

III.2.3 Problems relating to lack of clarity and

compatibility

- General comments

- Comments on lack of clarity of

specific clauses

- Comments on the compatibility of

specific clauses

- Overview of clause-specific criticism

III.2.4 Necessary tools

III.2.5 Lack of answers to questions

III.3 Evaluation

III.3.1 Further development of ISO 14001

requirements

III.3.2 Overall evaluation

III.4 Comments and suggestions

III.4.1 Certified organizations

III.4.2 Certifiers

III.4.3 Other interested parties

III.4.4 Findings of other surveys and

international experience

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Page 31

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Page 64

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Page 82

Page 83

Page 92

Page 93

Page 99

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I. Summary and overview

1 The two environmental management systems used in Germany are:• EMAS, an environmental policy instrument, valid across the European Union, with ca. 2500 validated

sites in Germany;• ISO 14001, a private-sector initiative, applicable worldwide, with ca. 2300 certified organizations in

Germany


Context:

Planned revision of the ISO 14001 environmental

management system standard

A revision of the ISO 14001 environmental management systems

standard is currently being negotiated internationally. The revision

process seeks to integrate the practical experience and results

gained by the users of the standard.

Pertinent reports and case studies are available from many countries

outside of the European Union. Within the context of the planned re-

vision, the German experience is now also of interest. To support the

development of a German position, the German Environment Min-

istry (BMU) and Federal Environmental Agency (UBA) initiated the

present survey and commissioned the Büro Dr. Glatzner consultancy

in Münster to carry it out.

The survey centres on the following questions:

- Is there a lack of clarity in the text of ISO 14001 that causes

problems for users?

- Are there problems of compatibility between the environmental

management system standard ISO 14001 and the quality man-

agement system standard ISO 9001?

- Is there a (future) need to modify existing or introduce new re-

quirements?

In order to be able to consider user experience and opinions within

the proper context, the study also examines issues that go beyond

the above questions. Similarly, it makes various references to the

European Eco-Management and Audit Scheme (EMAS). However,

the survey does not aim to compare the two systems.1

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I.Summary and overview

Background:

Survey participants – data and structures

In September 2000, the roughly 2300 ISO 14001 certified German organizations and all 34 accred-

ited German certification bodies were contacted. Each received a 4-page questionnaire (see page 21).

In addition to users and certifiers, representatives of industry, labour unions and environmental asso-

ciations were also surveyed. These had the opportunity to express opinions and make suggestions in

personal interviews.

Among the certified organizations, 565, i.e. about 25%, responded to the questionnaire. 17 certifica-

tion bodies, together responsible for some 90% of all certificates issued in Germany, also responded.

The organizations captured represent all sizes (in terms of number of staff and annual turnover) and

all industrial sectors. Worldwide and in Germany, the electrical and chemical sectors are leading – the

sectoral makeup of the survey respondents corresponds to this general sectoral distribution.

In Germany, 86% of the organizations surveyed also have certification to ISO 9001. In most cases the

quality management system was certified first. In addition, about half of the organizations captured

also have EMAS registration.

Situation:

User motivations and expectations

Most of the organizations surveyed are motivated to use ISO 14001 by internal reasons, external re-

quirements and – in many instances – a requirement by the parent company. The main reasons stat-

ed can be subsumed under the headings of ‘image enhancement’ and ‘customer/client requirement’.

The main benefits that the organizations surveyed expect ISO 14001 implementation to yield are: im-

proved organization, greater security in the law and enhanced image. While the internal improvements

were generally achieved in accordance with expectations, many respondents are rather disappointed

by the external benefits of certification (e.g. enhanced image, positive market effects).

Situation:

Human and financial resource allocations

Setting up an environmental management system to ISO 14001 takes 13 months on average, re-

quiring an internal workload of about 180 person-days and 30 external consultant days. The envi-

ronmental management system triggers environmental protection investments averaging DM 185,000

(e 95,000). Further costs of about DM 43,000 (e 22,000) are incurred for e.g. training, information

and auditing. In comparison, the savings achieved average DM 170,000 (e 87,000). However, only

few organizations appear to have precise cost figures, particularly concerning savings, but also the cur-

rent costs of the environmental management system.

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2 For an overview of all clauses of ISO 14001 see page 59.

Situation:

Resource allocation compared to other management systems

Compared to other management systems, setting up an ISO 14001 system is relatively less resource-

intensive. For instance, establishing a system to ISO 9001 or EMAS takes in each instance about 1

month longer: For one thing, EMAS poses additional requirements (e.g. environmental statement); for

another, ISO 14001 users profit from the groundwork and experience provided by the management

systems often already previously set up, which are at least partly transferable.

Problems:

User practice

The questionnaire gave the organizations surveyed the opportunity to express freely their concerns re-

garding the ISO 14001 standard. Considerable use was made of this possibility: A total of 795 com-

ments were received. The general comments on ISO 14001 range from criticism of the wording of the

standard through to calls for more explanatory examples and interpretation aids. The wish for align-

ment of ISO 14001 with ISO 9001 was expressed frequently. Moreover, arguments and views for and

against ‘integrated management systems’ were presented – this underscores the topicality and rele-

vance of this issue in the day-to-day operations of the companies.

In addition, many of the organizations surveyed complain about a lack of clarity concerning certain

terms or the corresponding specifications and requirements. Here concrete problematic clauses2 of the

standard are named, e.g. “Environmental aspects” (clauses 3.3 and 4.3.1) and “Operational control”

(clause 4.4.6), or the standard requirements concerning “Objectives and targets” (clause 4.3.3) and

“Management review” (clause 4.6).

Furthermore, the organizations surveyed voice fundamental criticism concerning the lack of compati-

bility between the management system standards ISO 14001 and ISO 9001: Here calls are made for

alignment, compatible structuring and uniform terminology.

The current difficulties experienced in practical integration or combination do not appear insur-

mountable, but the improvements desired could substantially facilitate the procedure. However, it

would appear that the true difficulties are not caused by lack of clarity in the standard text or lack of

compatibility with quality management standards – but rather by the high human and time resource

requirement and major documentation and administration effort associated with setting up and main-

taining an ISO 14001 environmental management system.

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Problems:

User perspective on necessary support and tools

The organizations surveyed use – in addition to the text of the standard and its explanatory Annex A –

various kinds of support and tools to implement ISO 14001. These include, in particular, guidelines

and seminars and also, in some cases, the text of the ISO 14004 standard, the EMAS Regulation and

specimen documentation. Many of the respondents also seek the support of external consultants –

some even find their services indispensable.

Nonetheless, almost half (48%) of all organizations surveyed have encountered questions concerning ISO

14001 that nobody could really answer. At all events, a quarter of them consider the available opportu-

nities to receive satisfactory answers to questions to be inadequate in Germany. Some wish a hotline,

helpdesk or similar institution.

Problems:

Certifier perspective on nonconformance

90% of the certifiers find a critical lack of conformity to standard requirements in more than 10% of

first-time audits of environmental management systems. High nonconformance rates continue to be

found in the subsequent surveillance audits and re-certification audits. Nonconformance mainly con-

cerns the sections on “Legal and other requirements” (clause 4.3.2), “Environmental aspects” (clause

4.3.1), “Objectives and targets” (clause 4.3.3), “Environmental management system audit” (clause

4.5.4) and “Training, awareness and competence” (clause 4.4.2).

Evaluation:

User and certifier perspectives on current status and future development

Overall, the ISO 14001 standard is evaluated positively: Using the German system of school marks

ranging from 1=‘very good’ to 6=‘unsatisfactory’, the organizations surveyed award the standard an

average mark of 2.7 across all grading categories. In these categories, the structure of the standard is

graded best (2.5), its clarity/comprehensibility less well (2.9); the grades for content/requirements of

the standard (2.6) and its compatibility with quality management standards (2.8) lie in-between.

95% of the organizations surveyed intend relatively definitely (“yes” and “rather yes”) to continue to

seek certification. The certifiers also anticipate dynamic further development – 41% of them expect

ISO 14001 certifications in Germany to triple by 2005, and 18% expect even higher growth rates.

78% of the certifiers surveyed estimate the proportion of organizations ‘opting out’ to be 10% or less.

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Opinions and suggestions:

Users

75.5% of the organizations surveyed take a positive view of the standard requirements and their fur-

ther development: They support making the auditing of actual compliance with environmental laws and

regulations (‘legal compliance’) a mandatory element of ISO 14001.

More than half of them also support calls to make the preparation of an environmental report manda-

tory within ISO 14001. This is a reflection of the circumstance that in Germany many ISO 14001 cer-

tified organizations also have EMAS-registered sites and already undertake these measures in any case.

The organizations surveyed also plead very clearly in favour of integrating environmental protection

more intensively in all functions and procedures, involving staff more closely and placing a stronger

focus on actual environmental performance.

A considerable number explicitly wish an expansion or detailing of standard specifications – through

to additional requirements, such as an initial environmental review, or environmental reporting. In ad-

dition, it is important to them that they gain more recognition and benefits from certification, partic-

ularly in terms of competitive advantages and state support. As a further point, they would welcome a

reduction of the resource allocation associated with the environmental management system or its cer-

tification, for instance in terms of documentation duties and certification costs.

Opinions and suggestions:

Representatives of industry, labour unions and environmental associations

Industry representatives note the following strengths of the ISO 14001 standard: its proximity to the

quality management systems already well known in the companies, its comparative openness to indi-

vidual implementation and its worldwide validity. They propose keeping the standard stable for a

lengthier period and clarifying over the medium term whether specific system standards will still be

justified or whether the future belongs to an integrated management system.

The German labour unions consider that the application of environmental management systems also

affects employee interests. They therefore call for improvements within the revision process – notably

relating to issues of legal compliance, performance and staff participation.

The criticism voiced by the environmental associations goes in the same direction. In addition, they

call for more intensive external communication and provision of environmental information; here, they

view the European Community Eco-Management and Audit Scheme (EMAS) as a model.

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Recommendations:

Outcome of the survey – recommendations for revising ISO 14001

Building upon the findings of the survey, recommendations are made that should be considered with-

in the ISO 14001 revision process.

These recommendations are listed in detail on page 83. They essentially correspond to the core issues

of the revision process:

Removing lack of clarity by

reviewing and revising the unclear definitions and requirements identified and

improving compatibility by

aligning parts of ISO 14001 with ISO 9001.

Further recommendations are concerned with

improving staff involvement by

underscoring their importance and introducing corresponding specifications,

reducing cost and effort by

reviewing where and to what extent documentation is necessary,

providing additional information by

expanding the examples and explanations in the annex to the standard,

expanding the toolbox of the ISO 14000 series,

improving external effect by

expanding the toolbox of the ISO 14000 series.

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II. The survey

German Environment Ministry /German Federal Environmental Agency

... “We attach great importance to the revision of the

ISO 14001 environmental management system standard,

and wish that the highest possible level is achieved in the

process of further developing this standard.”

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II. 1 Context

3 Pursuant to Council Regulation (EEC) No. 1836/93 of 29 June 1993. Now in a revised version as “EMAS II”: Regulation (EC) No. 761/2001 of the European Par-liament and of the Council of 19 March 2001 allowing voluntary participation by organizations in a Community eco-management and audit scheme (EMAS).

4 EMAS is limited to the European Union member states.5 See the “Speedometer” in the annex (also at www.inem.org) or the worldwide ISO 14001 certification statistics maintained by the German Federal Environ-

mental Agency (Umweltbundesamt, UBA) (also at www.14001news.de). The structure of the distribution of use is of course an outcome of the circum-stance that EMAS is a European system while ISO 14001 is an international standard.

6 As ISO 14001 specifies a management system, we may speak of an environmental management system standard or EMS standard (environmental manage-ment system is often abbreviated as EM system or EMS, in analogy to quality management system, QM system, QMS etc.).

7 www.iso.ch8 Unfortunately, there is no complete register of ISO 14001 certified organizations in Germany.9 Cf. Speedometer (www.inem.org), worldwide ISO 14001 certification statistics maintained by the German Federal Environmental Agency (Umweltbundesamt,

UBA) (www.14001news.de), ISO Survey (www.iso.ch), and the statistics of the Japanese standards institute (www.ecology.or.jp/isoworld).10 Currently, about a third of the organizations in Germany that have a certified environmental management system are only ISO 14001 certified, one third are

only registered under EMAS and one third have both ISO 14001 certification and EMAS registration.11 The table of contents of ISO 14001 gives an impression of the specifications – cf. www.14001news.de

II.1.1

The environmental management

standard ISO 14001

The growing complexity, scope and importance of

environmental requirements have triggered a

search among companies and organizations for

ways to reduce environmental impacts in an in-

creasingly systematic, efficient and effective

manner. Environmental management systems

have been developed and have become a con-

stituent part of environmental activities. In the

past, these systems were often developed individ-

ually by each company or organization, with very

different focuses and levels of maturity. Today, es-

tablished models are often used.

In Europe and Germany, EMAS, the European

Eco-Management and Audit Scheme, has been

available as such a model since 1995.3 Similarly,

the internationally developed and disseminated

standard ISO 14001:1996 “Environmental Ma-

nagement Systems – Specification with Guidance

for Use” has been in place since 1996. Both sy-

stems are recognized and in widespread use in

Germany and Europe, albeit with different focu-

ses. Worldwide, ISO 14001 is naturally4 the key

standard.5

The environmental management standard ISO

140016 was developed between 1993 and 1996

by the International Organization for Standardiza-

tion (ISO7) Technical Committee (TC) 207 “Envi-

ronmental Management” and adopted through an

international voting process.

By the end of 2000, more than 23,000 certifica-

tes had been issued according to this standard. It

is estimated that by early 2001 about

2400–2600 ISO 14001 certificates had been is-

sued in Germany; when the survey reported here

was conducted in September 2000, the figure

was approx. 2300.8

Germany thus ranks second behind Japan, where

some 5500 organizations have been certified.9

The same ranking applies for the total figure of

audited environmental management systems.10 In

terms of certifications per capita and per unit

gross domestic product (GDP), Germany ranks

12th and 13th11 (if EMAS sites are included, it

ranks 9th and 10th, respectively).

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II.1Context

ISO 14001 is one of a series of

ISO standards on environmental

management.12 The current stan-

dards in the series can be catego-

rized as follows:

The ISO 14001 “Environmental

Management Systems” standard

belongs to the group of stan-

dards used for independent cer-

tification. It is thus a tool used

worldwide to furnish proof of an

effective environmental man-

agement system that conforms

to the specifications of the stan-

dard13 and has been audited

and certified by independent

certifiers.

In Germany, activities relating to

the ISO 14000 series are con-

ducted by the Standardization

Committee for Basic Principles

of Environmental Protection

(Normenausschuss Grundlagen

des Umweltschutzes, NAGUS) of

the German Institute for Stan-

dardization (DIN).14 NAGUS was

constituted on the basis of an

agreement concluded in 1992

between the German Environ-

ment Ministry (BMU) and DIN

concerning the integration of en-

vironmental issues into stan-

dardization.

NAGUS represents German in-

terests in ISO/TC 207. It is

steered by an advisory council.

Its subcommittees comprise

representatives of industry and

academia, environmental ad-

ministration, environmental and

industry associations, technical

supervisory and advisory bodies,

labour unions and consumer

groups. These elaborate, in con-

12 The series is listed with full titles at www.iso.ch; cf. also the publication list of the German Institute for Stan-dardization (DIN) in the annex.13 The table of contents of ISO 14001 gives an impression of the specifications – cf. www.14001news.de14 See also www.din.de

Figure 1 The ISO 14000ff standard series

By category, listing the respective subcommittee (AA) within theresponsible German standardization committee (DIN-NAGUS)

Category Standard Sub-committee

Organizational evaluation

Environmental management ISO 14001 AA2systems ISO 14004 AA2

ISO/TR 14061

Environmental auditing ISO 14010 AA2ISO 14011 AA2ISO 14012 AA2ISO 14015 AA2

Product evaluation

Environmental labels ISO 14020 AA4and declarations ISO 14021 AA4

ISO 14024 AA4ISO/TR 14025 AA4

Life cycle assessment ISO 14040 AA3ISO 14041 AA3ISO 14042 AA3ISO 14043 AA3ISO/TR 14047 AA3ISO 14048 AA3ISO/TR 14049 AA3

Mixed organizational and product evaluationEnvironmental performance ISO 14031 AA5evaluation ISO/TR 14032 AA5

Integrating environmental aspectsinto product development ISO/TR 14062 AA1

Terminology ISO 14050

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II.1Context

sensus, German proposals relat-

ing to standardization projects.

With the aim of conducting

standardization work systemati-

cally and ensuring adequate

German participation in ISO/TC

207 activities, NAGUS has set

up the following subcommit-

tees:

NAGUS Subcommittee 2 (Ar-

beitsausschuss – AA2) with its

Working Group 1 (Unteraus-

schuss – UA 1) is responsible for

dealing with and pro-

viding inputs to the

ISO 14001 revision

process; it is the

counterpart to the

ISO TC 207 Subcommittee SC 1,

whose Working Group WG1 is

concerned with the ISO 14001

revision process.

Figure 2 The German Standardization Committee for Basic Principles of Environmental

Protection (DIN-NAGUS)

Subcommittees, responsibilities and international counterparts(Subcommittee SC= Arbeitsausschuss AA)

ISO – International Organization for Standardization

TC 207 – Technical Committee 207: Environmental Management

NAGUS – Normenausschuss Grundlagen des Umweltschutzes

DIN – Deutsches Institut für Normung e.V.

SC 1EnvironmentalManagementSystems

SC 3EnvironmentalLabelling

SC 4EnvironmentalPerformanceEvaluation

SC 5Life-CycleAssessment

SC 6Terms andDefinitions

EnvironmentalManagement,Environmental Auditing

AA 2

EnvironmentalLabels

AA 4

Environmental Perfor-mance Evaluation

AA 5

Life Cycle Assessment

AA 3

SC 2EnvironmentalAuditingand RelatedEnvironmentalInvestigations

ww

w.3

fdes

ign.

de

Comment by survey respondent:

“… the English texts are

better and clearer than

the German versions!”

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II.1Context

II.1.2

Planned revision

Under ISO rules, a regular re-

view is conducted of whether

and to what extent there is a

need to revise existing ISO stan-

dards. The review of ISO 14001

identified a need for revision,

and resulted in a revision deci-

sion by the responsible ISO

Committee TC 207. The process

of amending ISO 14001 com-

menced officially in Stockholm

on 16 June 2000. The revision

is to be completed by 2003 or

2004 at the latest.

According to ISO resolutions,

the present revision is not in-

tended to modify substantially

the requirements of the stan-

dard but rather to resolve com-

patibility problems and remove

any lack of clarity.15 In contrast,

the parallel revision of ISO

14004 “Environmental Man-

agement Systems – General

Guidelines” is pursuing a broad

approach, with a more intensive

substantive debate on require-

ments and methodologies for

their implementation.

Because ISO 14001 – in con-

trast to ISO 14004 – is used as

the basis for certifying thousands

of organizations, it has a binding

quality and importance far be-

yond that of a guideline.16 Con-

sequently, the revision of ISO

14001 must be conducted with

particular attention towards and

responsibility for the users.

The responsibility of this stan-

dardization process for reducing

environmental impacts is just as

great. The attractiveness, quali-

ty and level of the standard’s re-

quirements will determine how

many organizations worldwide

set up environmental manage-

ment systems, which ultimately

serve to prevent the environ-

mental impacts associated with

their activities, products and

services.

15 The debate on compatibility generally centres on the issue of compatibility between the EMS standard ISO 14001 and the QMS standard ISO 9001.16 Through the integration of ISO 14001 EMS requirements into EMAS II, they have even gained statutory character in Europe.

Figure 3 ISO 14001 revision schedule

Provisional timeline Milestones

June 2000 Beginning of revision

July 2001 1st Working Draft (WD1)

Nov. 2001 – anticipated 1st Committee Draft (CD1) expected

June 2002 – either 2nd Committee Draft (CD2)– or Draft International Standard (DIS)

June 2003 – if DISJune 2004 – if CD2 Completion as new ISO 14001 standard

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II.2.1 Goal

The goal of the study was to sur-

vey the experience and ideas for

revision of German companies

and organizations which use or

are certified to ISO 14001, in

order to support the develop-

ment of a German position in

the international revision pro-

cess. Comparison with EMAS

was not a part of the study.

In accordance with the ISO TC

207 terms of reference (see be-

low), the survey concentrated on

identifying any unclear points in

ISO 14001 and problems of

compatibility between the ISO

14001 environmental manage-

ment standard and the very

widespread ISO 9001 quality

management system standard.17

These issues were not to be ex-

amined in isolation, but rather

within the context of the practi-

cal experience of standard users

and certifiers. It was not an aim

of the study to carry out a com-

prehensive examination of the

environmental effectiveness of

environmental management sys-

tems set up in accordance with

ISO 14001, and thus no such

examination was conducted.

II.2.2

ISO TC 207 terms of

reference

ISO membership is made up of

the national standards insti-

tutes, such as the German Insti-

tute for Standardization (DIN).

The main actors as well as tar-

get groups of the management

system standards and thus also

of the revision process are

those that (want to) implement

ISO 14001 as users within

their organization.

In addition, there is a multi-

tude of interests and implica-

tions that play an explicit or

underlying role: differing goals

and needs of differently devel-

oped countries worldwide, pub-

lic interest in environmental

protection, the business inter-

ests of consultants and certi-

fiers, the needs of employees

affected by management sys-

tems, the interest in equality in

competition etc.

From a German perspective, the

aim is to integrate the German

position on the issues that will

and can be covered in the revi-

sion process. This needs to be

based upon the official ISO

terms of reference for the revi-

sion process:18

The revision of ISO 14001 is

limited to consideration of is-

sues related to compatibility of

ISO 14001 with ISO 9001 and

to clarification of the existing

text of ISO 14001. Any changes

to the existing text should help

understanding and implementa-

tion by users without resulting

in additional requirements in

ISO 14001. The revision of the

standard will be guided by the

following list of principles: sim-

plicity; clarity; effectiveness and

efficiency; impact on resource

allocation; meets the aims of

the standard; flexibility of the

standard; ease of use of the

standard; impact on existing

users; verifiability; not increas-

ing bureaucracy; compatibility

with the other elements of the

standards; compatibility with

ISO 9001; take special account

of the needs of SMEs; impact on

developing countries and trans-

latability.

In addition, it was agreed,

...that any identified issues

which are not dealt with within

its current revision process and

II.2 Goal and organization of the survey

17 In industrial practice, the quality management systems with which users have gained experience are in most cases currently still based upon ISO 9001:1994.This will remain so for a certain transitional period. The revision process, in contrast, refers to the current ISO 9001:2000 version.

18 Resolutions 3/2000 and 8/2000 of ISO TC 207 SC1.

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II.2Goal and organization ofthe survey

Figure 4

any issues which the members of SC1 identify as

potential new issues in environmental manage-

ment are recorded for future analysis.

The debate on revision thus essentially centres on

the following questions:

• Is there a lack of clarity in the text of ISO 14001

that causes problems for users?

• Are there compatibility problems between the

environmental management system (EMS) stan-

dard ISO 14001 and the quality management

system (QMS) standard ISO 9001?

• Is there a (future) need to modify existing or in-

troduce new requirements?

II.2.3 Target groups

These questions make clear that the survey must

centre on those who are involved directly in ap-

plying the standard, i. e. have to read and under-

stand it, integrate it into existing systems and,

last but not least, meet its requirements: the

companies that have themselves certified. As a

second main group, the experience of the certi-

fiers is important, who have to interpret the stan-

dard and use it as a basis for their auditing work.

On top of this, there are further target groups

whose experience and ideas can provide valuable

contributions to the further development of the

standard:

Target groups of the survey “ISO 14001 in Germany”

Target group Findings sought Organizations and Methodsindividuals surveyed

Certified - Difficulties in use All traceable organizations Questionnaireorganizations - Need for development certified in Germany

- Costs/benefits- Suggestions for improvement

Certifiers - Difficulties in use All certifying bodies Questionnaire- Difficulties in auditing accredited in Germany- Need for development as well as certifying

environmental verifiers

Other interested Appraisals and contributions Experts in German - Interviewsparties to a common German position - accreditation bodies, - Discussions

- business associations, in the responsible

- labour unions, standardization

- environmental organizations committee (NAGUS)

Page

19


II.2.4 Issues and questions

It follows from the goal of the study that the em-

pirical survey must focus on identifying the pro-

posals for revision or further development of ISO

14001 that flow from the experience gained in

the standard’s practical use. It was therefore es-

sential to give users the opportunity to comment

on practical difficulties, on the clarity of the text,

its compatibility and further development, and to

declare their position. An additional aim of the

study was to identify further problematic areas

and proposals for improvement by means of de-

termining the costs and benefits of ISO 14001

use and of the tools employed.

In order to generate meaningful results, all certi-

fied organizations in Germany and all certifiers

(who can be regarded as experts on the standard

as a basis for certification) were to be given the

opportunity to take part in the survey. Because of

the size and unity of these target groups, a writ-

ten (postal) survey through a questionnaire was

chosen.

Depending upon the issue under consideration, dif-

ferent types of questions can be posed. Closed

questions with preformulated answers are one type.

The survey also placed special emphasis on ample

opportunity and space for open comments and thus

open questions, despite the greater effort that this

involves (both in responding to and evaluating the

questionnaires).

Specific attributes of survey participants (‘struc-

tural data’) are surveyed in order to characterize

the group captured and assist in interpreting the

results. Reasons for certification give an impres-

sion of the situation of the organizations surveyed,

and can explain certain assessments of and com-

ments on ISO 14001.

The survey of costs and benefits associated with

using ISO 14001 delivers a picture of the advan-

tageousness of this environmental management

system. A poor cost-benefit ratio is indicative of

critical points in the system. It is further assumed

that a more or less positive cost-benefit assess-

ment will influence respondents’ overall evalua-

tion of the standard or its text, and their propos-

als for further development.

Experience teaches that implementing and oper-

ating a certifiable management system in accor-

dance with standard requirements is a demanding

task for those people in charge of it in an organi-

zation. Difficulties that may arise can be due ei-

ther to a lack of clarity in the standard’s text or to

a lack of compatibility or capability for integration

of the system. These issues need to be queried di-

rectly, together with other potentially problematic

points.

Furthermore, through open questions, partici-

pants had the opportunity and space to name spe-

cific parts of ISO 14001 (as chapters or key-

words) which seem unclear to them or where they

see problems of compatibility with their quality

management system.

Where specific difficulties arise with the stan-

dard, be it because of lack of clarity in the text or

because of compatibility problems, it can be as-

sumed that certain tools will be used for support.

The use of certain tools indicates which avenues

and measures are taken to implement ISO 14001

appropriately within the company, and is thus an

indicator of potential critical points in the stan-

wishes and suggestions that

they would like to see taken into

account in the revision of the

standard. In addition, partici-

pants were to provide an overall

evaluation of the standard.

Figure 1 gives an overview of the

survey elements:

Figure 5

Page

20


dard. Unresolved questions of

users regarding the standard

point to a lack of clarity and to a

lack of possibilities for clarifica-

tion.

Questions were also posed re-

garding the possible further de-

velopment of the standard

which could be answered by

ticking preformulated answers.

The purpose of this was to de-

termine whether a need is seen

for fundamental modification or

expansion of the standard. Sur-

vey participants were to be giv-

en the opportunity to express

Structural datacharacteristic attributesof respondents

Reasonsfor seeking certification

CostsOrg

in time and money

EvaluationProposals for revision

Implementationpractical difficulties

NonconformanceCert

deficiencies identifiedby certifiers

Lack of clarityRev

in the text of the standard

CompatibilityRev

with ISO 9001

Toolsused and recommended

Questions unresolvedeven after successful certification

CommentsWishes and suggestionsof respondents

Structure of the survey “ISO 14001 in Germany”

BenefitsOrg

anticipated and achieved

Difficultiesregarding

Background information

Certonly certifiers

Orgonly certified organizations

ww

w.3

fdes

ign.

de

RevImportant issues for ISO 14001 revision

RequirementsRev

Need for modificationor new issues

Page

21

II.2Goa and organization ofthe survey

For almost all elements, both

companies and certifiers can

provide information. However,

only the companies were asked

about the costs and benefits of

using ISO 14001, while the cer-

tifiers are able to provide valu-

able information on nonconfor-

mance of environmental man-

agement systems with the re-

quirements of the standard. All

other questions – partly modi-

fied – can be directed towards

both target groups, enabling di-

rect comparison between the as-

sessments based on different

experience.

A draft questionnaire was elabo-

rated, and then optimized tak-

ing into account the results of

and comments on pretests by

experts and company represen-

tatives.

For reasons of acceptance, in

order to minimize the workload

and to have a high return rate,

care was taken to keep the

questionnaire as short as possi-

ble and as long as necessary.

The 14 questions with about

100 subcategories filled only

four or, respectively, five pages.

Page

22


Figure 6

Questionnaire forcertified organiza-tionsreduced in size

Figure 7

Questionnaire for certifiersreduced in size

Page

23


Page

24


Questions to the accreditation bodies:

• Does the revision of ISO 14001 impact upon the

accreditation bodies and their tasks?

• What does ISO 14001 and its further develop-

ment mean to the certifiers?

• Do you have comments and suggestions con-

cerning ISO 14001, the certification of environ-

mental management systems and the admis-

sion/accreditation system?

The experience and proposals of other target

groups were surveyed by means of structured in-

terviews. The two German accreditation bodies,

the unions and representatives of environmental

and industry associations were surveyed in their

capacity as ‘interested parties’. Interviews pro-

ceeded from the following guiding questions

(see Fig. 8).

These questions were intended to

present an opportunity and en-

courage the institutions surveyed

to express their appraisals, ex-

pectations and ideas concern-

ing ISO 14001 revision, thus

providing a synopsis of the Ger-

man position that goes beyond

direct user interests.

Questions to the associations:

• What is the impact of ISO 14001 and its further

development upon you (as union/environmental

organization/industry association) and your

work?

• Which role can ISO 14001 play for the further

development of corporate environmental per-

formance (in Germany/Europe and worldwide)?

• What do you think are the strongest and weakest

points of ISO 14001?

• Which comments and suggestions do you have

for the current revision?

Figure 7

continued


Figure 8

Guiding questions forthe interviews withinterested party rep-resentatives

Page

25

II.3.1

Certified organizations

Worldwide, the registration and

central collection of data on or-

ganizations certified to ISO

14001 is common practice. The

accreditation guidelines19 valid

in Germany and applied by the

TGA (see on the TGA below) re-

quire that accredited certificati-

on bodies keep a register of cer-

tified organizations (including

address, date of certification,

registration number, scope of

validity etc.). Thus, in principle,

these data should (or must) be

available.

However, so far there is no cen-

tral, publicly accessible databa-

se of certified organizations in

the German ISO 14001 certifi-

cation system.20

Thus, for the survey conducted

here, no central database with

the relevant information was

available. Further fundamental

difficulties arose from the fact

that ISO 14001 certificates are

issued to ‘organizations’: These

can be organizational units of

any kind, subdivision and size.

The rough estimate of 2300 ISO

14001 certificates in Germany

was taken as a starting point. In-

terviews with experts, corporate

reports and press releases, envi-

ronmental reports and reference

lists etc. were used to identify

the addresses of the organiza-

tions that appeared to be certi-

fied. Altogether, 2308 organiza-

tions were identified and con-

tacted, of which 22 responded

explicitly that they were not cer-

tified to ISO 14001.

The questionnaires were sent out

with a cover letter and addressed

return envelope on 7 Septem-

ber 2000 and during the follow-

ing days. A small number of ad-

dresses that came in at a later

stage were included subse-

quently. The questionnaires were

to be completed and returned by

5 October. A dedicated website

(www.14001news.de) was es-

tablished for the project, provid-

ing support and information for

participants. This also made it

possible to refer queries to the

information available there.

In total, 565 questionnaires

were returned. In relation to the

2286 certified organizations

that had been contacted (2308

units minus the 22 ‘mistaken’

units), this represents a return

rate of 25%.

In fact, however, these 565

questionnaires cover more than

25% of the certified organiza-

tions and certificates. On the

basis of the explicit statements

by those centrally completing

the questionnaire for several

certified organizational units,

and proceeding from plausible

conclusions and attributions of

contacted and responding units,

it was possible to establish that

the 565 questionnaires repre-

sent roughly 900 certificates. If

one questionnaire represents

one company, this would mean

that, on average, there are about

1.5 certificates per company.21

A large certification body has

detailed information indicating

that the ratio of sites to certifi-

cate averages 1.7:1. It must

therefore be assumed that the

above number of certificates re-

presents an even larger number

of sites. If we take a factor of

1.5, we can broadly assume22

the following correlation:

II.3

Survey coverage

19 Cf. “Allgemeine Anforderungen an Stellen, die Umweltmanagementsysteme begutachten und zertifizieren” (General requirements for bodies operating as-sessment and certification/registration of environmental management systems – ISO/IEC Guide 66) e.g. at www.tga-gmbh.de.

20 In the following, “organization”, “organizational unit” and “company” are used synonymously unless the special organizational character is elaborated upon.21 Cf. Dyllick/Hamschmidt (2000) p.23f., who assume that the 348 ISO 14001 certificates that had been issued by the date of their survey in Switzerland were

spread among “some 290” companies (i. e. a factor of 1.2).22 The depicted correlation between the number of certified companies, the total number of certificates issued and the number of sites covered by these cannot

be established with certainty.

Page

26

II.3Survey coverage

II.3.2 Certifiers

In total, there are in Germany23 262 accredited

institutions or individuals who, within the frame-

work of a recognized accreditation procedure, are

entitled to certify organizations according to ISO

14001. These include 34 certification bodies

accredited according to international accreditati-

on rules by the German Association for Accredita-

tion (Trägergemeinschaft für Akkreditierung

GmbH – TGA). These are joined by a further 237

environmental verifiers or environmental verifier

organizations, which have been accredited by the

German Association for the Accreditation and Ad-

mission of Environmental Verifiers (Deutsche Ak-

kreditierungs- und Zulassungsgesellschaft für

Umweltgutachter mbH – DAU) pursuant to EMAS

and the German Environmental Auditing Act (Um-

weltauditgesetz – UAG). They are entitled to audit

organizations according to EMAS, and also accor-

ding to ISO 14001 in its function as a standard

recognized by the European Commission.

Environmental verifiers can consequently certify

companies to ISO 14001, in their capacity as so-

called ‘UAG-certifiers’ with DAU-accreditation,

without needing to have TGA-accreditation. Nine

certification bodies are accredited by both Ger-

man institutions.

23 This survey only covers certifiers accredited by the bodies mentioned; other certifiers who have been accredited abroad also operate in Germany in addition.

Figure 9 Estimated correlation between ISO 14001 certified companies, certificates issued

and certified sites in Germany (2000)

Organizations Certificates Sitescertified Factor issued Factor certified(number) (number) (number)

Estimated ratio 1 x 1.5 1.5 x 1.5 2.25

Surveyrespondents 565* x 1.5 ca. 900 x 1.5 ca. 1300

Total ca. 1500 x 1.5 ca. 2300* x 1.5 ca. 3450

*figures ascertained empirically

Page

27

II.3Survey coverage

All certifiers are registered, and

the register of accreditation is

publicly accessible.24 In total,

45 questionnaires were sent to

all TGA-accredited certification

bodies (34) as well as to a se-

lection of environmental verifier

organizations (11) which were

known to conduct ISO 14001

certification.

Between October 2000 and

January 2001, 23 completed

questionnaires were returned,

which equals a return rate of

51%. 12 of the 17 certifiers

that stated the number of cer-

tificates issued by them, i. e.

71% of these 17, had issued

less than 100 ISO 14001 cer-

tificates at the time of the sur-

vey; 5 of the 17 (i.e. 29%) can

be regarded as ‘very large certi-

fiers’, having issued more than

100, in some cases more than

500 certificates. These very

large certifiers account for

1699 (84%) of the total of

2025 ISO 14001 certificates

issued by the 17 respondents.

These 2025 ISO 14001 certifi-

cates captured by the survey of

the certifiers correspond to a

capture rate of 89% when

based on the 2286 organiza-

tions certified at the time of the

survey.

24 The list of TGA-accredited certifiers is available on the website of the TGA (www.tga-gmbh.de). The accredited environmental verifiers can be found on thewebsite of the DAU or of the Association of German Chambers of Industry and Commerce (www.diht.de).

Figure 10

VerifiersVerifiers

34TGA-accredited certifiersfor QMS and EMS standardsTGA = Trägergemeinschaft für Akkreditierung (German Association for Accreditation)

237DAU-accreditied environmental verifiersfor EMAS and ISO 14001DAU = Deutsche Akkreditierungs- und Zulassungsgesellschaft für Umweltgutachter(German Association for the Accreditation and Admission of Environmental Verifiers)

25EMScertification bodies

18Environmentalverifierorganizations

9bothcertifiers andenvironmentalverifiers

210Environmental verifiers

≈1300ISO 14001certified organizations

≈1300EMAS-validated sites

≈1300both

Certification auditors

ww

w.3

fdes

ign.

de

Overview of TGA-accredited and DAU-accredited environmental auditors

and relationships between them and the organizations audited

Page

28

II.3Survey coverage

II.3.3 Other interested parties

A revision of ISO 14001 concerns not only the users in a nar-

rower sense – the companies and certifiers. It also affects, di-

rectly or indirectly, the bodies responsible for accrediting certi-

fiers in Germany, and, in particular, company employees and those

sections of the public affected by the specific use of the environment.

The unions can be viewed as the representatives of the employees, and environmental organizations

as the representatives of the affected public. In addition, an overall appraisal was to be requested from

an association of German industry, in order to give expression to those voices not directly involved in

the standardization process or the ISO 14001 system. Well-known environmental management experts

from these circles and individuals known to represent their organization in these matters were asked

for an interview. Interviews were conducted with:

The managing directors of the TGA – Dr. Facklam – and the DAU – Dr. Racke.

“The accreditation bodies view ISO 14001 certification as an important

market for certifiers, and one that is set to grow; however, no marked rise

in the number of accredited certification bodies is anticipated.”

Accreditation bodies

Page

29

II.3Survey coverage

A representative of the German Trade Union Federation (Deutscher Gewerk-schaftsbund – DGB, Dr.

Schneider) and of a German industrial union (Mr Bahr of the Industrial Mining, Chemistry, Energy

Union – Industriegewerkschaft Bergbau, Chemie, Energie – IGBCE).

“Requirements on employee participation are inadequate in ISO 14001.

Clear conditions of participation need to be created – this means access to

environmental information, sufficient qualification and real

opportunities for participation.”

The managing director of the umbrella organization of German environ-

mental organizations, the German League for Nature and Environment

(Deutscher Naturschutzring – DNR, Mr Röscheisen).

“The lack of external effect is a major deficiency; there is no requirement

to be accountable in a credible fashion through a verified environmental

statement.”

The responsible expert of the Association of German Chambers of Industry and Commerce (Deutscher

Industrie- und Handelskammertag – DIHT, Dr. Hüwels).

"For the Association of German Chambers of Industry and Commerce, the

issue of environmental management and environmental management sys-

tems is very important.”

The interviews took place in February 2001 on the basis of the structured guiding questions, which

were distributed to the interviewees beforehand. The results of the interviews feature in the evaluation

part of this report.

Labour unions

Environmental organizations

Industry associations

Page

30

III. Survey results


“... in practice, departmental heads do not know

which laws and regulations they must comply with.”


Page

31

III.1 Current situation

25 Cf. the annex; EAC is the industry sector code of the European Accreditation of Certification; EMAS uses the NACE Code which is based on Council Regula-tion (EEC) No. 3037/90 on the statistical classification of economic activities in the European Community.

Figure 11 Industrial sectors of the organizations captured by the survey

(EAC Code Nos. 1-39)

1 Agriculture, fishing2 Mining and quarrying3 Food products, beverages and tobacco4 Textiles and textile products5 Leather and leather products6 Wood and wood products7 Pulp, paper and paper products8 Publishing companies9 Printing companies

10 Manufacture of coke & refined petroleum products11 Nuclear fuel12 Chemicals, chemicals products & fibres13 Pharmaceuticals14 Rubber and plastic products15 Non-metallic mineral products16 Concrete, cement, lime, plaster, etc.17 Basic metal & fabricated metal products18 Machinery and equipment19 Electrical and optical equipment20 Shipbuilding21 Aerospace22 Other transport equipment23 Manufacturing not elswhere classified24 Recycling25 Electricity supply26 Gas supply27 Water supply28 Construction29 Wholesale & retail trade; repairs of motor vehicles,

motorcycles & personal & household goods30 Hotels and restaurants31 Transport, storage and communication32 Financial intermediation, real estate, rental33 Information technology34 Engineering services35 Other services36 Public administration37 Education38 Health and social work39 Other social services

10

301104

120952

807

40136

66347402

266

16621

10

61

19254

26623

22

n=559Number of respondentsNo. Sector

ww

w.3

fdes

ign.

de

III.1.1 Structural data of organizations and individuals surveyed


The industry sectors of the organizations covered by the survey were identified according to the EAC

sector code25, as used in the certification and accreditation system.

Page

32

III.1Current situation

The table26 illustrates the main

sectors represented in the sur-

vey: Chemical industry (EAC 12),

electrical and optical equipment

(EAC 19), basic metal and fabri-

cated metal products (EAC 17).

Rubber and plastic products

(EAC 14), machinery and equip-

ment (EAC 18) and the food in-

dustry (EAC 3) are also strongly

represented.

In addition to the EAC sector

classification, the classification

according to broad branches of

industry was also surveyed. This

found that 74% of respondents

count themselves as belonging to

industry, 19% to services/trade,

3.5% to crafts and a further

3.5% to other categories (e.g.

agriculture, public authorities).

In the course of the above-men-

tioned analysis of the entirety of

ISO 14001 certified organiza-

tions in Germany, it was possi-

ble to ascertain the EAC Code

classification for some of these

(n=1449). Comparison with

this incomplete group shows

that the sector distribution in

the present survey only has a

slight over-rep-

resentation of

EAC 17 (basic

metal and fabricated

metal products) and a slight

under-representation of the

electrical and chemical indus-

tries. This balanced structure,

in conjunction with the high

capture rate of more than 25%,

supports the assumption that

the informative value of the sur-

vey results for Germany is high.

Surveys compiled

by ISO and by Ja-

pan, the ‘leading’

country in terms of ISO

14001 certifications, provide

statistics permitting a sectoral

comparison:27

26 Here and in the following tables or figures, ‘n’ is the number of responses that could be analysed.27 Cf. ISO Survey (www.iso.ch) and the statistics of the Japanese institute for standardization (www.ecology.or.jp/isoworld).


“... the standard should support all

users in achieving real improvement

of performance, and concentrate not

so much on improving the system ..."

Page

33


Figure 12

24%

9%

7%

7%7%3%

43%

Electric machinery

Chemical industry

General machinery

Service

Transportation machinery

Metal products

Other

Source:Japanese NationalCommittee for ISO TC 207

in Japan 2000n=5,222

21%

10%

6%

4%4%4%

51%

Electrical and optical equipment (EAC Code No. 19)

Chemicals, chemical products & fibres (EAC Code No. 12)

Machinery and equipment (EAC Code No. 18)

Other services (EAC Code No. 35)

Other transport equipment (EAC Code No. 22)

Basic metal & fabricated metal products (EAC Code No. 17)

Other

Source:ISO Survey – Ninth Cyclesee www.iso.ch

Worldwide 1999n=10,881

20%

20%

7%

5%4%

7%37%







Other

Source:Own research

in Germany 2000n=1,449

13%

14%6%

5%5%

11%

46%







Other

Source:Own survey

in the present survey “ISO 14001 in Germany”n=559

Industrial sectors of ISO 14001 certified organizations:

Worldwide; in Japan; in Germany; covered by the present survey (EAC Code)

Page

34


The present survey mirrors well

the sectoral distribution of ISO

certified organizations world-

wide. The general strength of

the electrical and chemical in-

dustries is striking – among both

the surveyed group and organi-

zational units certified in Ger-

many in general, as well as in

Japan and worldwide. However,

the informative value of this

overview and of the comparison

is limited. The data of the ISO

survey do not seem to be entire-

ly valid: For instance, the num-

ber of German certificates in

1999 is stated to be only 962,

which is probably too low28;

moreover, only 10,881 of the

14,106 certificates captured

worldwide have been classified

in industry sectors. The Japa-

nese industry sector statistics

are not based on the EAC sys-

tem with 39 sectors, but upon a

classification in 47 sectors, to

which all certifications are as-

signed. The data base of the

German ISO 14001 population

is incomplete and possibly bi-

ased, as only a sub-group

(n=1449) could be classified

according to sectors.

Regarding size classes in terms

of number of staff, the organiza-

tions represented in the survey

are distributed relatively evenly.

Here, as before, no accurate da-

ta is available on the attributes

of the population of all certified

organizations in Germany.

28 Other sources report about 1400 ISO 14001 certified organizations in Germany in 1999, cf. Umweltbundesamt (Federal Environmental Agency): EG-Umwelt-audit in Deutschland, Berlin 1999, p.16.

Figure 13

1-14 15-99 100-249 259-499 500-999 1000-5000 more

Frequency (n=560)

Number of staff

23

88

100 103

87

47

Size of the organizations in the survey

by number of staff

112

0

120

80

60

40

20

100

Page

35


The size-class distribution of the

group of organizations surveyed

correlates well with that of other

surveys of users of environmental

management systems in Ger-

many.29

The mean annual turnover of the

companies surveyed figures DM

1500 million (e 750 million).

Turnover ranges from companies

with DM 0.5 million (e 0.26

million) to the multinational with

DM 136,000 million (e 70,000

million). One third of the com-

panies is in the size class be-

tween DM 10 and 99 million

turnover, another third between

DM 100 and 500 million.

36% of the respondents stated

that they generate a certain per-

centage of their turnover on the

world markets outside the Euro-

pean Union (EU). About 10%

make more than 1/3 of their en-

tire annual turnover on these

markets.

Of the remaining third, the

smaller part is made up of com-

panies with less than DM 10

million turnover, the other part

being large companies with an

annual turnover of more than

DM 500 million.

29 Cf. e.g. Umweltbundesamt (Federal Environmental Agency): EG-Umweltaudit in Deutschland, Berlin 1999, p.25.

Figure 14

Figure 15

31%

21%

35%

13%

below DM 10 million

DM 10-99 million

DM 100-500 million

above DM 500 million

Size of the organizations in the survey

by turnover

15%

2%

8%

64%

no orientation to world market

up to 10% of turnover

10-33% of turnover

34-66% of turnover

more than 66% of turnover

11%

Proportions of organizations surveyed with turnover

generated outside the European Union

and the share of this in company turnover

Page

36


The following overview presents

the ‘certification status’ of the

organizations surveyed. Alto-

gether 86% of the organizations

are not only certified to the en-

vironmental management stan-

dard ISO 14001, they also have

a certification to a quality man-

agement standard of the ISO

9000 series. 51% of the re-

spondents have also undergone

EMAS validation. 23% of all re-

spondents have certificates to

further standards and require-

ments (such as QS 9000, VDA

6.1, SCC, EfbV).30

The ISO 9000 series came into

force in 1994. In terms of the

history of the standards, quality

management and the certifica-

tion of quality management sys-

tems is several years ahead of

the analogous development in

the environmental sphere.


systems pursuant to ISO 14001

are (on average) the ‘youngest’

management systems. The

longest experience comes from

quality management systems,

which, on average, were certi-

fied three years earlier. The time

required for implementation –

from decision to first certifica-

tion – was longest for quality

management systems, namely a

good 14 months; this was possi-

bly due to a lack of prior experi-

ence.

Only 7% of the companies sur-

veyed have been audited to ISO

14001 alone (see figure 17). In

contrast, 93% have a manage-

ment system certified to several

standards at once. 51% have

both ISO 14001 certification

and EMAS registration; 86%

have a quality management sys-

tem certified to the ISO 9000

series in addition to ISO 14001.

30 QS 9000 as well as VDA 6.1 are sector-specific extensions of ISO 9001 for suppliers in the automotive industry; SCC is a safety standard in the oil industry;EfbV is a certification according to the German Ordinance governing waste management contractors.

Figure 16 Certification status of the organizations surveyed in Germany

(as of October 2000)

First certification/ Time from decisionCertification status Percent validation until 1st certification

n=563 Month/Year Month Ø

ISO 14001 100% 7/1998 13

ISO 9001 orISO 9002 orISO 9003 86% 8/1995 14

EMAS (Eco-Managementand Audit Scheme) 51% 12/1997 14

Others 23% 1/1998 11

Page

37


Within each combination, there

are varying histories. It is evident

that in those organizations that

have a certified quality manage-

ment system next to their envi-

ronmental management system,

the order is: quality management

first, then environmental man-

agement. Often, ISO 14001 and

EMAS were introduced and certi-

fied or validated at the same

time. In some instances, the cer-

tification of environmental and

quality management systems

was combined. Respondents

thus mostly have long-standing

experience with several manage-

ment system standards.

Figure 17 Management system combinations applied by the organizations surveyed

and their chosen sequence of introduction

Combination Share Sequence of introduction Numbern=560 simultaneous: a/b in succession; a before b: a b n=485

ISO 14001 only 7% ISO 14001 3939

ISO 14001 EMAS 2ISO 14001 EMAS ISO 14001 8and EMAS 7% ISO 14001/EMAS 25

38 35

ISO 14001 ISO 9001 10ISO 14001 ISO 14001/ISO 9001 54and ISO 9001 42% ISO 9001 ISO 14001 154

237 218

ISO 14001 EMAS ISO 9001 2EMAS ISO 14001 ISO 9001 2ISO 14001/EMAS ISO 9001 6EMAS ISO 9001 ISO 14001 6ISO 14001/EMAS/ISO 9001 17

ISO 14001 ISO 9001 ISO 14001 EMAS 20and ISO 9001 ISO 9001 EMAS ISO 14001 56and EMAS 44% ISO 9001 ISO 14001/EMAS 94

246 203

Page

38


Certifiers

A total of 23 accredited certi-

fiers or EMAS environmental

verifiers participated in the

study. Among the EMAS veri-

fiers, 8 have only TGA accredi-

tation and 6 are pure environ-

mental verifiers (DAU); 9 state

that they have the accreditation

of both institutions. This means

that, in total, the participants in

the survey represent 17 TGA ac-

creditations and 15 DAU ac-

creditations.

The certifiers only certifying en-

vironmental management sys-

tems are a minority. 16 of the

23 participants are accredited

to certify both QM systems and

EM systems.

26% of the certifiers state that

they work mainly in the EAC 17

sector (basic metal and fabricat-

ed metal products), 17% in the

EAC 12 sector (chemicals,

chemical products and fibres).

The ‘big five’ certifiers (partici-

pating in the survey), who repre-

sent about 1700 ISO 14001

certificates issued, have their

focus on EAC 3 (food products,

beverages and tobacco), 12

(chemicals, chemical products

and fibres), 17 (basic metal and

fabricated metal products), 18

(machinery and equipment), 19

(electrical) and 22 (transport

equipment). Certain sectors, no-

tably in services, do not repre-

sent a sectoral focus of certifiers

Figure 18 Accreditation status of ISO 14001 certifiers in Germany

taking multiple accreditations into consideration

Percen- Date ofStatus Number tage accreditation(n=23) multiple accreditations possible average

TGA certifiers of EM systems 17 74% 6/1997

DAU env. verifiers/verification bodies 15 65% 2/1996

TGA certifiers of QM systems 16 70% 3/1995

Figure 19

Page

39


at all; these include the building

industry, catering trade, financial

services and data processing.

25% percent of certification au-

dits are ISO 14001 audits only,

31% combine ISO 14001 certi-

fication with EMAS validation

and 39% combine ISO 14001

with QMS certification.

The certifiers thus adapt to the

requests and circumstances of a

majority of their clients, who in-

tegrate different goals and

tasks, such as environmental

protection, quality management

and safety aspects, into their

management system and want it

certified according to recog-

nized standards.

Combinations of different management systems in certification audits

according to certifiers

Combination PercentageMean values

Single auditISO 14001 25%

Combined auditISO 14001 and EMAS (European Eco-Management and Audit Scheme) 31%

Combined auditISO 14001 and ISO 9001 31%

Combined auditISO 14001 and ISO 9001 and others (e.g. SCC) 8%

Others 5%


“… in EMAS, the aspects to be addressed are

described much better, and the specifications on

environmental impacts are clearer.”

Page

40


31 Corresponding to the research design, the results presented here and in the following are based partly on the survey of organizations and partly on the surveyof certifiers. Where both groups were asked about the same issue, the certified organizations’ experiences are paramount while the experiences of the cer-tifiers play an ac-cessory role, since the main target group of this survey (and of the revision of the standard) are the users in the certified organizations.

32 The main reasons given by the participants in an unstructured way have been aggregated thematically here.

Figure 20

2%

60%

Yes

No

Don’t know

38%

External reasonsn=435

1%

48%

Yes

No

Don’t know

51%

Requirement of parent companyn=382

2 %

81%

Yes

No

Don’t know

17%

Internal reasonsn=471

Reasons for setting up an ISO 14001 environmental

management system

from the perspective of the organizations surveyed

III.1.2 Reasons for

using ISO 14001

The reasons for introducing an

ISO 14001 management sy-

stem are diverse. For the orga-

nizations31 surveyed, internal

reasons, such as envisaged

organizational improvements,

were evidently the key reason for

introducing ISO 14001. Next to

this, external reasons, such as

client or customer require-

ments, frequently also played a

role. In half of the cases, the

implementation of an environ-

mental management system is

attributable quite simply to the

requirement by the parent com-

pany to do so.

Of those which confirmed only one

of these three reasons (143 of

the 471 respondents=30%), 92

(64%) stated purely internal rea-

sons, 32 (22%) purely external

reasons and 19 (13%) a require-

ment by the parent company. Mo-

tivations are thus certainly multi-

layered. The following main rea-

sons32 for implementing an envi-

ronmental management system to

ISO 14001 were stated explicitly

by 277 of the organizations in the

survey (see Fig. 21).

The reasons for setting up a cer-

tified ISO 14001 environmental management system33 can be as-

sumed to speak in favour of retaining it, too.

Page

41


The certifiers were asked which

might be the decisive reasons

for ‘maintaining’ certification or

possibly ‘opting out’.

According to the certifiers, opting

out is mostly a question of:

• discontinued client/customer

or market requirements,

• organizational changes (clos-

ing down, takeover etc.),

• lack of incentives (deregula-

tion, external effect ...), or

• an unfavourable overall cost-

benefit relation.

According to the certifiers, certi-

fication is mostly maintained in

order to

• fulfil prevailing client/customer

requirements,

• optimize and improve the trans-

parency of internal processes,

promote system performance

and the continual improve-

ment process and

• generate internal benefit (secu-

rity in the law, cost reduction).

33 Where we speak of an “ISO 14001 environmental management system”, this means an environmental management system that is implemented and certifiedaccorduing to ISO 14001;“setting up” the system, and “maintaining” or “opting out” from it therefore always has to be understood within the context ofcertification.

Figure 21 Main reasons for setting up an ISO 14001 environmental management system

from the perspective of the organizations surveyed

Reason Number Percentagen=277

1. Image(... PR, good example, credibility, marketing ...) 49 18%

2. Requirement by customer/client(... market requirement, competitive advantage ...) 43 16%

3. Corporate philosophy(... responsibility, sustainability ...) 31 11%

4. Continual improvement(... system, process and organizational improvements ...) 26 9%

5. Security in the law(... legal compliance ...) 20 7%

6. Universality(... acceptance of the standard, worldwide validity ...) 19 7%

7. Integrated management(... link to quality management, to workplace health and safety, synergies ...) 16 6%

8. Cost savings(...cost-effectiveness ...) 14 5%

9. Recognition(... demonstrate performance ...) 10 4%

10. Link to EMAS(... supplement to EMAS, by-product ...) 9 3%

11. Various 40 14%

Page

42


III.1.3

Benefits

expected by users

The responses of the partici-

pants in the certified organiza-

tions to the question of which of

the given categories of benefit

they had expected and which

actually emerged show whether

the reasons stated for imple-

menting and maintaining an

ISO 14001 certified environ-

mental management system

were confirmed and whether ex-

pectations were met or not.34

The main benefits expected

from the implementation of an


tem were improved organization,

greater security in the law and

enhanced image.35

34 Here and in the following, values (e.g. 1, 2, 3) were attributed to the answer categories (e.g. yes, part-ly, no) and depicted as means over all answers; cf. the detailed analyses in the annex.

35 The results correspond closely to those of the study by the Federal Environmental Agency; the ques-tions of that study were used for better comparability, cf. Umweltbundesamt (Federal Environmen-tal Agency): EG-Umweltaudit in Deutschland, Berlin 1999, p.37.

Figure 22 Benefits

Expected and actual benefits from setting up an ISO 14001environmental management system in the organizations surveyed

Mean values

1 32

Enhanced image

Greater security in the law

Improvedorganization/documentation

Plant safety

Positive market effects

Improved cooperation withauthorities

Use of public funding

Optimization of processes

Organizations

Employee motivation

Setting good example for suppliers

Less expensive insurance/credit

Competitive advantage/securedposition

Cost savings

Saved resources

yes nopartly

expectedactual

Page

43


The actual benefits were mostly

an improved organization/docu-

mentation and greater security

in the law. Regarding these,

there is little disappointment,

i.e. the difference between the

expected and actual benefit is

small. 78.7% of the participants

had expected an improved or-

ganization and documentation

and 68.2% found that this ex-

pectation was met. 74.4% had

expected greater security in the

law and 63.9% achieved it.36

The largest disappointments

arose in terms of lack of recogni-

tion: in general (image), among

clients/customers (market ef-

fects), authorities (cooperation),

employees (employee motiva-

tion), suppliers (setting good ex-

ample) and business partners

(insurance companies, banks).

In addition, expectations regard-

ing competitive advantage/se-

cured position and also regard-

ing cost savings were not met

entirely.

Only the benefits gained in

terms of plant safety fully met

expectations; this aspect, how-

ever, does not play any decisive

role as a reason for implement-

ing and maintaining an ISO

14001 environmental manage-

ment system.37

III.1.4

Resource allocation

and costs

The resources required to es-

tablish and maintain an ISO

14001 system can be assessed

from the data reported on hu-

man resources required and

costs incurred, minus the sav-

ings achieved:

The staff of the ISO 14001 cer-

tified organizations had to deal

with the implementation of the

ISO 14001 management sys-

tem for months until the first

certification: On average some

13 months passed from the de-

cision to the first certification

(for both ISO 9000 and EMAS

one month longer).

36 The detailed results, which are available as a separate data collection, are not included here, in order to focus on the core findings and key appraisals of theparticipants, and also for reasons of clarity and manageability of the report.

37 Cf. the section on “Reasons for using ISO 14001”.

Figure 23

013-18

Frequency (n=435)160

140

120

100

80

60

40

20

1-3 4-6 7-9 10-12 19-24 25-36 37-48

Time needed for necessary preliminary work until first

ISO 14001 certification

reported by the organizations surveyed

7361

17

2

40

156

68

18

1 Year 2 Years 3 Years1/2 Year 4 Years

Number of months

Page

44


During a 13-month implementa-

tion phase, 183 person-days are

required internally. If we assume

220 person-days for 12 months

(or 240 days for 13 months), we

find that one person has to use

75% of his or her working time

for 13 months in order to set up

an environmental management

system ready for ISO 14001 cer-

tification – or that three people

have to be employed for a quar-

ter of their working time for 13

months. According to estimates

of respondents, roughly 3 months

per year continue to be re-

quired on a regular basis to op-

erate or maintain the manage-

ment system.

The 35 working days of external

support needed in the course of

the implementation add up to

DM 42,000 (e 21,500) if a per

diem rate of DM 1200 (e 615)

is assumed. In their order of

magnitude, these findings con-

firm the figures determined by

other studies.38

Implementing an environmental

management system frequently

necessitates investment in fixed

assets, which the participants

estimate on average at about

DM 185,000 (e 94,600). In-

vestment in fixed assets cannot

be attributed directly as costs

of the environmental manage-

ment system. Such investment

is ‘only’ triggered by the intro-

duction of the system but is

based upon regulatory require-

ments, technological develop-

ments or cost-effectiveness as-

pects. The implementation of


tems does doubtlessly trigger re-

al operational efforts and im-

provement measures; these in-

cur costs, but can also generate

benefits such as cost savings.

The cost savings generated by

implementing the environmen-

tal management system, as esti-

mated by the respondents, add

up to DM 170,000 (e 87,000).

This is in the order of magnitude

of the investment triggered

(n=82).39

Respondents estimate the fur-

ther costs associated with first

certification (e.g. training, infor-

mation and auditing costs) to av-

erage DM 45,000 (e 22,500).

38 Cf. e.g. Umweltbundesamt (Federal Environmental Agency): EG-Umweltaudit in Deutschland, Berlin 1999, p.36.39 Within the given framework, most participants were unable to answer completely the questions regarding non-recurring and current expenditure and savings.

Data are evidently not available, only available elsewhere or in a different form.

Figure 24 Time needed to set up and maintain an ISO 14001 environmental management

system

estimated by the organizations surveyed

Resource allocation for setting up for maintenanceperson-days estimated person-days estimated, yearly

Internal staff 183 days 61 days

External support (consultants) 35 days 6 days

Page

45

III.2.1

General difficulties

Setting up and maintaining an


tem involves not only costs and

time spent. Various problems

can also arise in the implemen-

tation process. In order to as-

sess the role of “lack of clarity”

and “compatibility problems” in

this, survey participants were

asked about the difficulties that

arise when setting up and main-

taining an ISO 14001 system.

Both the certified organizations

and the certifiers were asked.

Various preformulated answers

were offered, including “unclear

requirements of the ISO 14001

standard text” and “difficult in-

tegration into existing systems”.

III.2 Current problems

Figure 25 Difficulties in setting up and maintaining the ISO 14001 system

Views of organizations and certifers

Mean values

1 32

Mean values

1 32

Difficulties in integrating all relevantstaff

Lack of methods for analysis andevaluation

Major consumption of human and timeresources

Unclear requirements of the ISO 14001standard text

High cost of resulting environmentalaction

Major documentation andadministration effort

Difficult integration into existing systems

yes no

Organizations Certifiers

partly yes nopartly

setting up

maintaining

setting up

maintaining

Page

46

III.2Current problems

From the point of view of the or-

ganizations, lack of clarity in the

standard, difficulties with inte-

gration, the lack of analytical

and evaluation methods, the

cost of the resulting environ-

mental protection measures and

the integration of staff are not

major problems. The main prob-

lems are the human and time

resources needed especially

during the initial implementa-

tion phase as well as the docu-

mentation and administration

effort associated with the ISO

14001 system.

The assessment of the certifiers

differs only slightly. Regarding

the implementation of the sys-

tem, they see not only the hu-

man resources, time and docu-

mentation needed but also – dif-

fering from the self-assessment

of the organizations – difficulties

resulting from the lack of analyt-

ical and evaluation methods es-

pecially in the initial implemen-

tation phase as well as the ques-

tion of integrating all relevant

staff. Certifiers have a greater

tendency to see staff integration

as a problem not limited to the

initial implementation phase.

Overall, it is apparent that a lack

of clarity regarding the text and

possible problems regarding in-

tegration due to incompatibili-

ties may be practical problems

of ISO 14001 but they are by no

means crucial for the partici-

pants in this survey. The high in-

put of human and time re-

sources as well as the documen-

tation and administration effort

that comes with setting up and

maintaining the ISO 14001 sys-

tem are viewed as much greater

problems.

III.2.2

Nonconformance

An environmental management

system in an organization – even

if it was implemented “accord-

ing to ISO 14001” – can devi-

ate from the requirements of the

standard. During audits – which

can be first-time audits, regular

surveillance audits or audits for

re-certification – certifiers regu-

larly detect typical so-called

nonconformances. These are in-

stances of non-compliance with

the requirements of the stan-

dard that can be classified as

‘non-critical’ or ‘critical’. Criti-

cal nonconformance is partly or

entirely an obstacle to success-

ful certification and needs to be

remedied by an organization be-

fore it can receive the certifi-

cate.

Nonconformance is an indicator

of difficulties experienced in

meeting the requirements of the

standard. These may be due to

the requirements themselves,

lack of clarity, or problems with-

in the organization. 19 out of

21 certifiers (90%) find non-

conformances which are a hin-

drance for immediate certifica-

tion in 10% of the first-time au-

dits. 6 out of 22 certifiers even

find critical nonconformances

which make immediate certifi-

cation impossible in over 50%

of the first-time audits. But

even during the surveillance au-

dits after certification, noncon-

formance is found on a regular

basis. Here, still one third of the

certifiers find critical nonconfor-

mance by 10% of their clients.

47% of the certifiers find this

10% nonconformance rate

again in re-certification audits.

Page

47


The most important nonconformances the certifiers find revolve

around the following requirements of the standard:

Figure 26

Figure 27

0

Number (n=435)

Proportion of audits finding ‘critical nonconformance’

12

10

8

6

4

2

≤ 5% ≤ 10% ≤ 25% ≤ 50% > 50%

First-time audits

Surveillance audits

Re-certification audits

Proportions of certification audits in which ‘critical

nonconformance’ is found

Data supplied by certifiers

‘Critical nonconformance’ in ISO 14001 implementation by German organizations

Findings by certifiers in ISO 14001 audits

Critical nonconformances Mentions Percentagemore than10 mentions (n=20)

1. Legal and other requirements (clause 4.3.2) 16 80%

2. Environmental aspects (clause 4.3.1) 14 70%

3. Objectives and targets (clause 4.3.3) 12 60%

4. Environmental management system audit (clause 4.5.4) 11 55%

5. Training, awareness and competence (clause 4.4.2) 10 50%

Page

48


Deficiencies in handling legal

and other requirements (sub-

clause 4.3.2 of ISO 14001) top

the nonconformance list. Certi-

fiers especially find non-compli-

ance with legal requirements or

that legal requirements manage-

ment does not meet the require-

ments of the standard (identifi-

cation of relevant environmental

laws and regulations, implemen-

tation and control, tracking of le-

gal requirements).

Often, there are problems with

the standard requirements re-

garding environmental aspects

(subclause 4.3.1) – in some in-

stances, not all significant envi-

ronmental aspects are identified,

characterized and evaluated ap-

propriately; in others, no connec-

tion is made between the signifi-

cant aspects and operational

control.

Judging from the nonconfor-

mance found, the users also have

problems with the requirements

regarding objectives and targets

(subclause 4.3.3). In some cas-

es, objectives are rated as inade-

quate because targets are not

specified sufficiently, the organi-

zation’s environmental policy and

significant environmental as-

pects are not taken into account,

no continual improvement pro-

cess is apparent or the whole pol-

icy-objectives-programme-review

control circuit does not work.

The certifiers base their work on

the (internal) environmental

management system audit (sub-

clause 4.5.4). Often, though,

there are faults in the auditing

process which can be due to the

fact that the audit is not under-

stood as a method, is conducted

with too little focus on environ-

mental aspects or too superficial-

ly, inappropriate auditing proce-

dures are chosen or the neces-

sary independence of auditors is

lacking.

Finally, the area of training,

awareness and competence

(4.4.2) is a weak point often

found by the certifiers. Partly, the

necessary training is not con-

ducted, partly the competence or

the necessary awareness of staff

does not exist and partly there is

a general lack of integration and

motivation of staff.

Beyond these main nonconfor-

mances, the following elements

are mentioned sporadically (be-

tween 4 and 8 answers each):

operational control (4.4.6), man-

agement review (4.6), structure

and responsibility (4.4.1), emer-

gency preparedness and re-

sponse (4.4.7) and nonconfor-

mance and corrective and pre-

ventive action (4.5.2).

The underlying reasons for this

are: detected nonconformances

in environmentally relevant pro-

cesses, problems with the man-

agement review especially re-

garding its informative value and

its quality of actually activating

top management, faults regard-

ing responsibilities (management

representative), weak points re-

garding emergency analysis and

preparedness as well as insuffi-

ciently implemented and func-

tioning corrective actions.

Page

49


III.2.3 Problems relating

to lack of clarity and

compatibility

Given the focus of the revision

defined by ISO TC 207, ques-

tions relating to possible lack of

clarity within ISO 14001 and

compatibility of ISO 14001

with ISO 9001 are at the centre

of attention in both the revision

process and the present study.

The survey sought not to limit

the expected criticism, ideas

and suggestions for improve-

ment regarding these aspects to

a catalogue of pre-defined an-

swers. Structured questions with

pre-defined answer categories

have the advantage of being easy

to answer and analyse. The par-

ticipants, though, cannot voice

their views directly. They cannot

set their own focus and intro-

duce new aspects.

For these reasons, there were

two open questions in the ques-

tionnaire, i.e. questions without

pre-defined answers. Firstly, the

“lack of clarity” and “compati-

bility problems” of ISO 14001

were queried. Secondly, the par-

ticipants were asked at the end

of the questionnaire to express

“other wishes and comments”.

Out of the 563 organizations

covered by the survey, 300 par-

ticipants took the opportunity to

comment openly on lack of clar-

ity and compatibility, and gave

395 answers with a total of 795

comments.40

The comments were subsumed

and counted under generic

headings. This is the only way to

generate universal statements

and findings. While the single,

individually formulated com-

ments ‘disappear’ under these

generic headings, they are

nonetheless the ‘backbone’ of

the interpretation of the results

and are thus present in the eval-

uation and recommendations.41

There were 82 comments from

the certifiers. 37 of these were

general comments and 45

clause-specific comments re-

garding lack of clarity of ISO

14001 and its compatibility

with ISO 9001.

40 Cf. the overview of comments by certified organizations in the annex.41 The individual suggestions and comments have been passed on to NAGUS, the DIN committee responsible for the ISO 14001 revision process.


“… it is essential to align 14001 with 9001:2000

(in its new, process-focused version)!”

Page

50


General comments

The following table shows the

categories of general comments

which were made by the partici-

pants in ISO 14001 certified or-

ganizations regarding lack of

clarity of ISO 14001 and its

compatibility with ISO 9001.

The general comments show

that there are users who have no

problems with the clarity and

compatibility of the ISO 14001

standard. It becomes clear as

well, though, that the majority

of the participants had some

(critical) comments regarding

these issues.

Comments range from criticism

regarding language (“poor Ger-

man translation”) over the wish

for more concreteness (“too

general”) to specific sugges-

tions (“more examples and sup-

port for interpretation request-

ed”); some contradict others

(“abridge” – “elaborate”).

Sometimes just explanation is

requested, regardless of word-

ing. For instance, the meanings

of “shall”, “shall not”,

“should”, “should not” in their

German translations do not

seem to be clear to all of the

users.

The frequent general request for

more description and support

for interpretation can be met to

a large extent by ISO 14004 –

which is also under revision at

present – as a general guideline.

In the view of the organizations,

the annex and specific refer-

ences to ISO 14004 and other

standards remain matters to be

tackled within ISO 14001.

The comments on the compati-

bility of ISO 14001 with ISO

900142 make clear that com-

patibility is, on the one hand, a

key issue for the users and, on

the other hand, the question of

compatibility has long present-

ed itself in practice as a general

issue of integration:

Often, an alignment of the stan-

42 The participating organizations generally referred to the currently valid version ISO 9001:1994, which is used in practice; only few comments referred to thenew version ISO 9001:2000.

Figure 28 General comments on problems of clarity in applying ISO 14001 and problems

of compatibility with ISO 9001

Mentions by organizations

Comments Mentions Percentagemultiple (n=260)

1. Text of ISO 14001 and lack of clarity 99 38%

2. Compatibility of ISO 14001 with ISO 9001 73 28%

3. For and against integration 71 27%

4. Explicitly no problems of clarity or compatibility 17 7%

Page

51


dards is desired, be it an align-

ment of structure and clause

numbering or be it the terms

used or the process structure.

Partly, the requests go beyond

this to the demand to take over

several clauses of ISO 9001

without changing the wording.

In addition, cross-references be-

tween the standards are sug-

gested.

Environmental management and

quality management (and the

standards used) or their com-

patibility or incompatibility are

by no means the only issues for

users. Now, the concern is to in-

tegrate entrepreneurial tasks

(environmental, health and

safety, security etc.) into the ex-

isting management system. The

standards should at least not

stand in the way of these issues

of integration. But they should

also not pre-empt specific deci-

sions for integration, as the re-

sponses “for and against inte-

gration” underscore. For some,

the ‘integrated management

system’ is the goal while others

see the danger that existing dif-

ferences and foci might be

blurred.

Next to general demands for a

more comprehensible language

and an even clearer structure of

the standard, the certifiers

made a few comments on the

question of compatibility. Ac-

cording to them, difficulties in

combining ISO 9001 and ISO

14001 mainly arise from the

different structure (“structure”,

“procedural structure”, “same

contents not in the same

places”) and the partly differing

terminology (“different terms for

the same contents”). In the view

of the certifiers, alignment

should be sought here.


“… textual clarity: We found no significant weaknesses.”

Page

52

Figure 29 Comments on problems of clarity in applying ISO 14001

Mentions by organizations

Comments Mentions Percentageon specific clauses of ISO 14001 (more than 10 mentions) multiple (n=206)

1. Environmental aspects (clause 4.3.1 = requirement) 27 13%

2. Operational control (clause 4.4.6) 19 9%

Environmental aspects (clause 3.3 = definition) 19 9%

4. Objectives and targets (clause 4.3.3) 13 6%

5. Management review (clause 4.6) 12 6%


Clause-specific

comments regarding

lack of clarity

In addition to general com-

ments, the participating organi-

zations made concrete com-

ments (n=206) regarding the

lack of clarity of specific claus-

es of the standard. These are

summarized under headings in

the following list, and then dis-

cussed on the following pages,

in juxtaposition to the original

wording of ISO 14001.

The list shows that the defini-

tion of and specifications con-

cerning “environmental as-

pects” (clauses 3.3 and 4.3.1

of the standard) were mentioned

particularly often. There is a rel-

atively large need here to pro-

vide clarification and delimita-

tion of this term, e.g. vis-à-vis

“environmental impacts”.


“…service providers have trouble interpreting the

terminology of the standard. These terms are

largely oriented to manufacturing companies.

There is a need in many cases for re-interpreta-

tion for service providers.”

Page

53


In the view of many users, the

specification of how to identify

“environmental impacts” is

generally “unclear”. In particu-

lar, users ask what the underly-

ing “significant environmental

impacts” actually are, and in

what detail the environmental

aspects to be evaluated must in

fact be identified. They ask

themselves how suppliers or

sub-contractors are to be treat-

ed and how legal requirements

are to be applied in this re-

spect. They miss criteria and

examples, although the text of

ISO 14004 provides explana-

tions. They wish that the envi-

ronmental aspects to be taken

into consideration were speci-

fied or recommended. To many,

the term “environmental as-

pects” (clause 3.3 of ISO

14001) is unclear in itself.

Excerpts from the text of ISO 14001:

“... 3.3 Environmental aspect:

element of an organization’ s activities, products

or services that can interact with the environment

Note:

A significant environmental aspect is an environ-

mental aspect that has or can have a significant

environmental impact. ...

... 4.3.1 Environmental aspects

The organization shall establish and maintain (a)

procedure(s) to identify the environmental as-

pects of its activities, products or services that

it can control and over

which it can be expect-

ed to have an influence,

in order to determine

those which have or

can have significant

impacts on the environ-

ment. The organization

shall ensure that the

aspects related to these

significant impacts are considered in setting its

environmental objectives.

The organization shall keep this information up-

to-date. …”


“… the definition of ‘significant environmental aspect’

is empty of meaning, examples would be useful (in

conjunction with 3.8); the same applies to 4.3.1.”

Environmental aspects

Clauses 3.3 and 4.3.1 of ISO 14001


“… on clauses 3.3/3.4,

there is a lack of criteria

for determining which

environmental aspects

are relevant/significant

and therefore must be

taken into considera-

tion.”

Page

54


Operational control

Clause 4.4.6 of ISO 14001

Excerpt from the text of ISO 14001:

“... 4.4.6 Operational control

The organization shall

identify those operations

and activities that are

associated with the

identified significant envi-

ronmental aspects in line

with its policy, objectives and

targets. The organization shall plan

these activities, including mainte-

nance, in order to ensure that they

are carried out under specified con-

ditions by

a) establishing and maintaining docu-

mented procedures to cover situa-

tions where their absence could lead

to deviations from the environmental

policy and the objectives and tar-

gets;

b) stipulating operating criteria in the

procedures;


“… the description of environmental targets

and of the environmental programme given

by the standard is woolly!”

Page

55


The sec-

tion on “Op-

erational control”

(clause 4.4.6) is a further focus

of criticism. Users miss advice,

examples and recommendations

that might clarify which opera-

tions are to be controlled in the

first place. The clause is evi-

dently “not formulated clearly

enough”, “misleading” in parts

for some, outlined "too briefly”,

“difficult to understand” or for-

mulated “impractically”. Survey

respondents wish to see a more

detailed description or examples

and suggestions of relevant op-

erations.

c) establishing and

maintaining procedures

related to the identifi-

able significant environ-

mental aspects of

goods and services

used by the organiza-

tion and communicating

relevant procedures

and requirements to

suppliers and contrac-

tors. …”


“… on 4.4.6, operational control: Simple, short

sentences, please – not complicated, multi-clause

ones!”

Page

56


Objectives and targets

Clause 4.3.3 of ISO 14001


“... 4.3.3 Objectives and targets

The organization shall es-

tablish and maintain doc-

umented environmental

objectives and targets,

at each relevant function

and level within the organi-

zation.

When establishing and reviewing its

objectives, an organization shall con-

sider the legal and other require-

ments, its significant environmental

aspects, its technological options

and its financial, operational and

business requirements, and the

views of interested parties.

The objectives and targets shall be

consistent with the environmental

policy, including the commitment to

prevention of pollution. …”


“… in ISO 14001, management goals are joined

by environmental targets: These are exaggerated

demands that are not appreciated sufficiently by

many staff members!”

Page

57


The complex surrounding “Ob-

jectives and targets” (clause

4.3.3) appears problematic: The

terms themselves are felt to be

“not self-explanatory” and the

pair of terms “difficult to com-

municate”; there is a lack of

sufficient characterization of

the required “scope”; it is un-

clear “in what detail” everything

must be presented and docu-

mented, and where the border-

line to the environmental pro-

gramme is. Some respondents

propose merging this clause

with that on the environmental

programme. In addition, reser-

vations are voiced regarding the

goal of continual improvement –

is this only about system im-

provement, and how long can

environmental per-

formance be improved

continually?


“… ‘Zielsetzungen und Einzelziele’ is a typically

German translation of standard wording that

seeks to embrace everything in the title and thus

becomes incomprehensible. ‘Vorgaben und Ziele’

would be a better rendering of ‘objectives and

targets’ …”

Page

58


Management review

Clause 4.6 of ISO 14001

“Management review” (4.6) is

unclear to many respondents in

terms of its “scope” or wording.

Some view this requirement as

“superfluous”, some call for

clear demarcation: What is (ter-

minologically, too) the relation-

ship between the internal audit,

the management review of the

management system and the

regular review of environmental

policy?


“... 4.6 Management review

The organization’ s top man-

agement shall, at intervals

that it determines, review the

environmental management

system, to ensure its continuing

suitability, adequacy and effective-

ness. The management review

process shall ensure that the

necessary information is col-

lected to allow management

to carry out this evaluation.

This review shall be documented.

The management review shall ad-

dress the possible need for changes

to policy, objectives and other ele-

ments of the environmental manage-

ment system, in the light of environ-

mental management system audit re-

sults, changing circumstances and

the commitment to continual im-

provement. ...”


“… on clause 4.2, environmental policy: What

does ‘appropriate’ mean? How do I review this?”

Page

59


Other clauses criticized, but

less frequently, are: structure

and responsibility (4.4.1), envi-

ronmental impact (3.4 under

the general heading of “Defini-

tions”), environmental manage-

ment programme(s) (4.3.4), le-

gal and other requirements

(4.3.2), envi-

ronmental

management

system audit

(4.5.4) and

documentation (4.4.4). This in-

cludes the very concrete ques-

tion, posed by several respon-

dents, of which position the

management representative

must have. Must he be appoint-

ed by top management, or must

he be a member of top manage-

ment, and how can small enter-

prises proceed here?

Certifiers see a lack of clarity

(for the organizations to be cer-

tified) in this order: environmen-

tal aspects (4.3.1 under the

general heading of “System re-

quirements”), operational con-

trol (4.4.6), legal and other re-

quirements (4.3.2), objectives

and targets (4.3.3 under the

general heading of “System re-

quirements”) and emergency

preparedness and response

(4.4.7). In all these aspects, the

argumentation of the certifiers

is similar to that of the organi-

zations, and concretization is

considered helpful.


“… the German term for ‘environmental perform-

ance’, ‘umweltorientierte Leistungen’: Who dreams

up this kind of terminology?”

Page

60


Comments on the com-

patibility of specific

clauses

Compared to the number of gen-

eral comments and clause-spe-

cific comments on lack of clari-

ty, there are less clause-specific

points of criticism and sugges-

tions regarding compatibility.

Out of the 295 comments by

participating organizations on

the open question about clarity

and compatibility problems, 10

(=3%) explicitly stated good

compatibility, 21 (=7%) re-

sponded by making general

comments on compatibility and

23 (=8%) made clause-specific

comments. If the specific com-

ments of the certifiers are

added, certain key issues can be

identified.

The following table lists the is-

sues commented upon by both

the certified organizations and

the certifiers.

Further specific comments by

the organizations were on “ob-

jectives and targets” (4.3.3),

“records” (4.5.3), “environmen-

tal management system docu-

mentation” (4.4.4), “document

control” (4.4.5), “nonconfor-

mance and corrective and pre-

ventive action” (4.5.2), “organi-

zation” (3.12), “environmental

policy” (4.2), “environmental

management programme(s)”

(4.3.4), “environmental man-

agement system audit” (4.5.4);

in addition, the participating

certifiers mentioned “environ-

mental aspects” (4.3.1) and

“implementation and operation”

(4.4).

In all these clause-specific com-

ments, impeded compatibility

or a need for harmonization with

ISO 9001 are mentioned only in

a very general manner.

Overview of clause-

specific criticism

The following table highlights

those clauses of ISO 14001

which received the most (criti-

cal) comments. Regarding both

“nonconformance”43 and “lack

of clarity”, five clauses of the

standard were criticized more

than ten times. Due to the gen-

erally small degree of clause-

specific criticism on “(in)com-

patibility”, those three clauses

are highlighted which were

mentioned by both the ISO

14001 certified organizations

and the certifiers.

43 Cf. the section on nonconformance in the present report.

Figure 30 Comments on problems of compatibility with ISO 9001

Mentions by organizations and certifiers

Comments Mentions Mentionson specific clauses of ISO 14001 Organizations Certifiers

1. Operational control (clause 4.4.6) 5 1

2. Emergency preparedness and response (clause 4.4.7) 2 2

3. Checking and corrective action (clause 4.5) 2 1

Page

61


Figure 31 Nonconformance, lack of clarity, incompatibility:

The criticized clauses of ISO 14001

Mentions by certified organizations and certifiers

Clauses of ISO 14001

3 Definitions3.1 Continual improvement3.2 Environment3.3 Environmental aspect3.4 Environmental impact3.5 Environmental management system3.6 Environmental management system audit3.7 Environmental objective3.8 Environmental performance3.9 Environmental policy3.10 Environmental target3.11 Interested party3.12 Organization3.13 Prevention of pollution

4 Environmental management system requirements4.1 General requirements4.2 Environmental policy4.3 Planning4.3.1 Environmental aspects4.3.2 Legal and other requirements4.3.3 Objectives and targets4.3.4 Environmental management programme(s)4.4 Implementation and operation4.4.1 Structure and responsibility4.4.2 Training, awareness and competence4.4.3 Communication4.4.4 Environmental management system documentation4.4.5 Document control4.4.6 Operational control4.4.7 Emergency preparedness and response4.5 Checking and corrective action4.5.1 Monitoring and measurement4.5.2 Nonconformance and corrective and preventive action4.5.3 Records4.5.4 Environmental management system audit4.6 Management review

Nonconformancecertifiers

Lack of clarityorganizations

IncompatibilityMentioned by both

Page

62


III.2.4 Necessary tools

Setting up an environmental

management system is a de-

manding and resource-intensive

task. Consequently, external ex-

perts are often consulted or oth-

er tools employed.

The following overview shows

which kinds of support and tools

the surveyed organizations have

used and whether they have

found them helpful.44

The official German edition of

the standard, DIN EN ISO

14001, includes the text and

the annexes in German and

English. Almost all participants

in the survey have used the text

of the standard. Those that have

not used the ISO 14001 stan-

dard (still 18%) must have re-

lied on external consulting or

gained ISO 14001 certification

‘in passing’ within the context

of their EMAS participation.

This is underlined by the high

degree of use of the EMAS Reg-

ulation (64%) (which, more-

over, is available free of charge).

In comparison, the guidance

standard ISO 14004 is used

less frequently; not even half of

the organizations (49%) have

made use of it.

Even general publications, guide-

lines and literature are used

more often; in addition, lectures,

seminars and training are at-

tended frequently. The support

of associations or chambers,

financial support or specific

44 To calculate the means only the valid answers could be used. It thus has to be accepted that there is a (slight) bias in the overview because the number ofvalid cases varies (slightly).

Figure 32

Mean values

1 32

Support and tools

used or found helpful when implementing ISO 14001 – view of

the organizations surveyed

Standard in different languages

Explanatory annex A

Text of the EMAS regulation

External independent consulting

Support by association/chamber

Publications/guidelines/literature

Manuals/examples

Lectures/seminars/training

Organizations

Financial support

Special software

Text of the ISO 14004 standard

yes nopartly

used

found helpful

Page

63


software are used relatively

rarely. In comparison, freelance

consultants are drawn upon of-

ten: 64% of all participating or-

ganizations have made use of a

consultant. The consultants are

generally seen as helpful, in

some cases even indispensable

as some comments have shown.

This indicates that the practical

application of environmental

management systems is a de-

manding task. It also supports

the comments of some respon-

dents that to implement ISO

14001 it is essential to use an

‘interpreter’.

For the certifiers,45 next to

using standards and other publi-

cations the “exchange with col-

leagues” plays an important ro-

le. They engage in this frequent-

ly and find it very helpful.

III.2.5 Lack of answers

to questions

Unresolved questions suggest

difficulties in understanding,

problems of definition and a

need for interpretation. Almost

half of the organizations have

experienced questions concern-

ing ISO 14001 which could not

be resolved unequivocally. Moreover, a large part of the organiza-

tions finds that the possibilities to receive satisfying answers to

their questions about the standard are insufficient. There is a defi-

nite need in this area.

The comments made in this regard call for e.g. a “hotline” or an

“information desk”. It would presumably be crucial that such an in-

formation office is authorized to answer questions on the interpre-

tation of the standard.46 Especially the certifiers, half of which are

of the opinion that the existing possibilities are not sufficient, could

benefit from such an institution.

45 The certifiers were given a slightly modified list of possible answers.46 For Germany, NAGUS would be responsible, which neither propagates this, nor develops a list of answers to frequently asked questions, nor has defined a

question-answer procedure (such as e.g. the American National Standards Institute has).

Figure 33

19%

56%

Yes

No

Don’t know

25%

Are there satisfactory opportunities for clarification?n=544

14%

48%

Yes

No

Don’t know

38%

Are there questions that nobody can really answer?n=549

Frequency of unresolved questions concerning ISO

14001 and evaluation of available opportunities for

clarification

View of organizations surveyed

Page

64

III.3.1

Further development of

ISO 14001 requirements


standard ISO 14001 reflects a

worldwide compromise based on

the state of the art of 1996. In

the meantime, rapid develop-

ment of concepts, instruments

and practical experience with


tems and tools has taken place

in Germany and many other

countries across the world. Addi-

tional standard requirements are

not on the agenda of the current

revision process. Nevertheless,

even small adjustments or termi-

nological considerations should

be embedded in a forward-look-

ing overall approach which in-

cludes elements that in some in-

stances are already common

practice. This is highlighted by

the following figure47 which

shows measures implemented

by German organizations in their

environmental management.

III.3 Evaluation

47 While the question on the practical application of certain measures was to be answered clearly with “yes” or “no”, the question regarding introduction as acompulsory element sought to identify tendencies through the answers “rather yes” and “rather no”.

Figure 34 Measures

Environmental management measures implemented and recommended, and their rating as desirableadditional requirements of ISO 14001 – from the perspective of certified organizations and certifiers

Mean values

1 21,2 1,4 1,6 1,8

Mean values

1 21,2 1,4 1,6 1,8

Preparation of environmental reports

Environmental costing & environmentalcost management

Use of environmental indicatorsystems

Product assessment, life cycleassessment

Suppliers’ obligation to implementan EMS

Verification of actual legalcompliance

Communication with external partiesabout objectives and env. perfomance

Use of environmentally oriented productdevelopment (DfE) tools

Yes (rather yes) (rather no) no


Yes (rather yes) (rather no) no

is used

should be mandatory

is recommended

should be mandatory

Page

65

III.3Evaluation

For the participating organiza-

tions, the following measures are

neither of great practical rele-

vance, nor are they an issue for

introduction as a mandatory ele-

ment of ISO 14001: “environ-

mental costing & environmental

cost management,” “product as-

sessment & life cycle analysis”

and “suppliers’ obligation to im-

plement an environmental man-

agement system.”

“Environmental indicator sys-

tems”, “communication with ex-

ternal parties” and “application

of DfE tools” are already prac-

tised and there is no distinct po-

sition against their introduction

as a mandatory element, with

one exception: A compulsory, ex-

ternally oriented communication

of targets and environmental

performance, which goes beyond

environmental reporting, is re-

jected by a strong majority (86%

of the answers) as a mandatory

element of ISO 14001.

“Verification of actual legal

compliance” and “preparation

of environmental reports”, al-

though not mandatory meas-

ures, have already been put into

practice by many of the organi-

zations. To the question whether

legal compliance auditing

should be a mandatory part of

ISO 14001, 75.5% responded

“rather yes” and 15.5% “rather

no”.48 In practice, this seems to

be largely matter-of-course49, as

laws and regulations must be

complied with in any case, and

one purpose of environmental

management systems is to en-

sure legal compliance.

While most respondents agree

on the question of “legal com-

pliance”, views on whether the

“preparation of environmental

reports” is a desirable element

of ISO 14001 are not as un-

equivocal. Nonetheless, 76.7%

of the organizations surveyed

prepare environmental reports

(for instance in the form of the

EMAS environmental state-

ment); and more than half tend

to support the introduction of

this element as mandatory in

ISO 14001 (this also holds for

47.3% of the organizations cer-

tified only to ISO 14001).

48 Cf. preceding footnote.49 The discussion on legal compliance (especially in Germany) is mostly about the question of to what extent a certificate confirms compliance with all relevant

regulations and, moreover, whether it can be sufficient to establish and certify system procedures or whether the actual compliance with relevant regula-tions has to be audited as part of the requirements for certification.

Figure 35 Legal compliance

in practice and its evaluation as an additional ISO 14001requirement – perspective of certified organizations

Percentage

0 10020 40 60 80

is carried out

should be mandatory

Verification of actual

legal compliance

Organizations

(rather) yes

(rather) no

no answer

87.7

75.5 15.5

9.2

Page

66

III.3Evaluation

The certifiers clearly recommend

the application of all measures

listed. They support making

mandatory the “preparation of

environmental reports”, the “use

of environmental indicators”, a

“suppliers’ obligation to imple-

ment an environmental manage-

ment system” and the “verifica-

tion of legal compliance”. They

rather reject, though, mandatory

environmental costing or obliga-

tory product-related measures

within the ISO 14001 system.

In order to broaden the perspec-

tive on future standard develop-

ment, the participants were pre-

sented with further, more basic

aspects of environmental man-

agement with respect to the fur-

ther development of ISO 14001.

Almost all principles established

in ISO 14001 (see the following

overview) were evaluated positive-

ly, i.e. were judged by most or-

ganizations and certifiers as im-

portant, with one substantial ex-

ception: The application of de-

manding technological standards

(e.g. “best available technology”

or “state of the art of technolo-

gy”)50 is rated as less important

and, from the point of view of the

participants, needs (should?!) not

be enshrined more firmly in the

standard in the future.

In contrast, the respondents

deem the following principles as

important and deserving support:

to integrate environmentally re-

sponsible action into all functions

and procedures, to integrate all

staff and to focus on actual envi-

ronmental performance and re-

sults.

The participating organizations

are rather reserved regarding the

integration of the supply chain

and a generally enhanced trans-

parency and external communi-

cation.

The certifiers – in contrast to

the certified organizations – find

the consideration of sustainabil-

ity criteria and the integration of

the supply chain into environ-

mental management important

and consider that these should

be strengthened. Furthermore,

they find the guarantee of an in-

dependent certification system

very important but see no need

for further reinforcement.

50 In Council Regulation (EEC) 1836/93 (EMAS I) the technological specification was the “economically viable application of best available technology”; the re-vision of EMAS removed this requirement. The level of “best available technology” corresponds to “Stand der Technik” (“state of the art of technology”)under German environmental law – cf. Feldhaus, Gerhard: Beste verfügbare Techniken und Stand der Technik, in: Neue Zeitschrift für Verwaltungsrecht,Frankfurt/Main 2001, 20.Jahrgang, Heft Nr.1, S.1.

Figure 36 Environmental reporting

in practice and its evaluation as an additional ISO 14001requirement – perspective of certified organizations

Percentage

0 10020 40 60 80

is carried out

should be mandatory

Preparation of

environmental reports

Organizations

(rather) yes

(rather) no

no answer

76.7

52.4 39.6

21.3

Page

67

III.3Evaluation

Figure 37 Evaluation of environmental management principles

from the perspective of certified organizations and certifiers

Mean values

1 21,2 1,4 1,6 1,8

Mean values

1 21,2 1,4 1,6 1,8

Integrate responsible action into allfunctions and procedures

Activate and integratestaff on all levels

Maintain public acceptance

Support innovation capacity and learningprocesses

Be flexible regarding differentorganizational forms and sizes

Ensure compliance with relevantenvironmental regulation

Integrate the supply chain into theenvironmental management

Take into consideration sustainabilitycriteria

yes (rather yes ) (rather no) no


yes (rather yes ) (rather no) no

Apply demanding technologies

Enhance transparency and externalcommunication

Focus on actual environmentalperformance and results

Ensure an independent certificationsystem

important

should be strengthened

important

should be strengthened

Report

for theEnvironmental management systems

standard ISO 14001

Aspect Grade

Clarity/comprehensibility of the text: 2.9

Compatibility with QMS standards: 2.8

Structure of the standard: 2.5

Content/requirements: 2.6

Overall grade: 2.7

awarded:by 473 German ISO 14001 certified organizations,October 2000

(School marks from 1 = ‘very good’ to 6 = ‘unsatisfactory’)

Page

68

III.3Evaluation

III.3.2 Overall evaluation

The users in certified organizations award ISO 14001 the following

report, which is based on German school marks ranging from 1

(very good) to 6 (unsatisfactory), including half grades:

The ISO 14001 standard thus receives a “good-to-satisfactory”

mark from the certified organizations. The report given by the cer-

tifiers is slightly better, especially because of a more positive judge-

ment of the standard’s structure, which was on average awarded a

grade of 2.2.

The satisfaction of those using the standard can also be measured by

a ‘migration quota’. This evaluation indicator is the quota of those or-

ganizations that want to continue with certification and those that

want to opt out.

If this is not an option for users, e.g. because of client/customer re-

quirements, another way of expressing user satisfaction is the voicing

of criticism and suggestions for improvement. Concerning the inten-

tion to continue certification, the survey found that:

More than 95% of the participating organizations respond to the

question about their intention to continue with certification with

“yes” (83%) or “rather yes” (12%).

This makes clear that there are permanently good reasons for keeping

up an environmental management system according to ISO 14001

and its certification.

1%

2%1%

83%

yes

rather yes

rather no

no

don’t know

no answer

12%

1%

Intention of organizations surveyed to continue

certification

Will you continue to seek ISO 14001 re-certification in the fore-seeable future?

Figure 38

Figure 39

Page

69

III.3Evaluation

The certifiers, too, anticipate a

dynamic development of ISO

14001 certifications: The majori-

ty expects at least a tripling of

certificates by 2005.

In contrast, the share of organiza-

tions opting out is estimated to be

low. A majority of certifiers is of

the opinion that in Germany, only

10% of the participants, at most,

will not opt for surveillance audits

and re-certification.

Ultimately, a positive decision in

favour of an environmental man-

agement system or its certifica-

tion and re-certification indicates

that the advantages of the system

outweigh its disadvantages and

costs. This does not mean,

though, that there is no room for

improvement that would increase

benefits or reduce costs.

Figure 40

Figure 41

18%

36%

5%

41%

less than doubling

about doubling

about tripling

more than tripling

Further development of number of ISO 14001

certifications

Estimates by certifiers

Number of mentions by certifiers (n=23)

Opting out

Proportion of those opting out of ISO 14001 in the future –estimates by certifiers

0

1

2

3

4

5

6

7

8

9

1% 2% 3% 5% 10% 15% 20%Proportion of organizations opting out

Page

70

III.4.1


The comments made by the par-

ticipating organizations under-

score that these consider an op-

timization of ISO 14001 desir-

able in several respects:

Out of the 563 participants,

306 commented. These com-

ments round off the question-

naire. The responses provided

on the participants’ own initia-

tive partly just confirm state-

ments made in other parts of

the questionnaire. In some cas-

es, though, the space was also

used to voice “other” comments

and suggestions that go beyond

the focus of this survey.

The largest complex of responses

(120=39%) can be summarized

under the heading “extension of

standard requirements”.

A large portion of these com-

ments (55 responses) refers to

suggestions for extending or de-

tailing the requirements of the

standard, namely: Mandatory en-

vironmental statement/environ-

mental reporting, an initial envi-

ronmental review, stronger orien-

tation towards performance and

results, emphasis on legal com-

pliance, introduction of methods

and tools (assessment methods,

inventories, eco-controlling, en-

vironmental indicators), consid-

eration of the products, of the

suppliers, of the risk/insurance

situation, strengthening internal

communication, obligation to

dedicate resources, integration

of ISO 14010.

Another issue often mentioned

(48 responses) was the align-

ment of ISO 14001 with EMAS.

This does not in every case mean

that the requirements of ISO

14001 should be raised; it could

also mean dropping the addi-

tional requirements of EMAS.

Central to these comments is

probably the desire to have only

one system without unnecessary

duplication of effort, multiple

auditing, terminological confu-

sion etc. – and with national and

international acceptance.51

Next to this ‘factual’ argumenta-

tion an ‘environmental policy’ ar-

gumentation can be seen in

some of the comments: Aligning

the standard with EMAS is hoped

to support the acceptance of ISO

14001 as a prerequisite to dereg-

ulation, and render superfluous

or displace EMAS. Some of the

participants (17 responses) ex-

pressed opposition to additional

III.4 Comments and suggestions

51 The revision of EMAS has fulfilled this wish to a great extent since EMAS II now contains the environmental management system requirements of ISO 14001.

Figure 42 Wishes and other comments of the organizations surveyed

Mentions Percentages(multiple) (n=306)

1. Extension of standard requirements 120 39%

2. Wishes regarding more recognition and facilitation 86 28%

3. Remarks on resource expenditure and costs 42 14%

4. Wishes regarding certifiers and certification 15 5%

5. Other comments and wishes 43 14%

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71

III.4Comments and suggestions

or higher requirements or an

alignment with EMAS.

The wish for stronger recogni-

tion and facilitation for ISO

14001-certified organizations

forms the second largest com-

plex of issues and was men-

tioned by 86 of the participants

(28%). This means general de-

mands for more attention and

public relations work but also

e.g. the possibility of advertis-

ing on products. Most of all,

though, facilitation in terms of

environmental law and regulato-

ry enforcement is desired. Next

to this, there is a wish for certi-

fication to be recognized posi-

tively in the placing of orders

and in public procurement. Tax

reductions are also mentioned.

Furthermore, calls are made to

remove the disadvantages due

to high German environmental

standards or the distortion of

competition due to varying envi-

ronmental standards abroad.

In third place (42 respons-

es=14%) are demands to re-

duce the resource expenditure

and financial cost associated

with applying the standard and

gaining certification. Especially

the cost of documentation is of-

ten criticized, but also the price

of the standard itself and the

cost of certification. Regarding

the latter, some participants

suggest that the annual surveil-

lance audit be removed and that

the frequency of external audits

be extended.

Wishes regarding certifiers and

certificates (15 responses=5%)

concern more consulting and

support by certifiers instead of

monitoring and formal inspec-

tions. It was also suggested to

issue neutral certificates which

are independent of the certifica-

tion body; according to some

suggestions, certificates could

also include more information

about environmental perform-

ance and the environmental

management system.

Other comments (43 respons-

es=14%) refer to a multitude

of different suggestions which

range from an improved consid-

eration of the situation of small

and medium-sized companies

to the wish to see German inter-

ests represented more strongly

in the standardization process

and the request to better coordi-

nate surveys in order to mini-

mize the workload for the organ-

izations involved.

III.4.2

Certifiers

The certifiers that made com-

ments call for, among other

things, the introduction of an in-

itial environmental review when

an environmental management

system is set up, the use of en-

vironmental indicators, an im-

proved measurability of environ-

mental targets and a stronger

consideration and evaluation of

actual environmental perfor-

mance. They are in favour of en-

hanced transparency e. g.

through the introduction of (vo-

luntary) environmental reports.

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III.4.3 Other interested parties

The following sections present summarized statements derived from interviews with accreditation bo-

dies, labour unions, environmental organizations and associations of German industry.52

Comments made by the accreditation bodies

• For the accreditation bodies (TGA, DAU), the revision of ISO 14001 is relevant at most with regard

to the admission and supervision of certifiers.

• In this context, those provisions that cover the certification process and the competence of certifiers

are more important to the accreditation bodies than ISO 14001.

• The new ISO 19011 standard (“Guidelines on quality and environmental auditing”), which is soon

due for publication, should not result in dilution of the requirements placed upon the qualification

of EMS certifiers.

• The accreditation bodies see an important market for certifiers in ISO 14001 certification, and are

of the opinion that this importance is set to grow; however, the accreditation bodies do not anticipate

any major growth in the number of accredited certifiers.

• Because of the increasing demand for information on the number and distribution of ISO 14001 cer-

tified organizations in Germany, the TGA is considering setting up a database, as is common prac-

tice in other countries.

• DAU, at least, sees no need to align ISO 14001 and EMAS (“We consider EMAS’ focus on environ-

mental performance, environmental law and environmental information as an attribute providing spe-

cial benefits and thus as a mark of quality distinguishing it from other systems”). Nevertheless, com-

patibility problems – e.g. regarding definitions – are recognized which make an alignment desirable.

52 Where interviewees had a focus that differed in some respects (e.g. the two accreditation bodies, the two union representatives), the present overview seeksto identify the common points in the statements made.

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Comments made by the unions

• Unions see their task in securing the interests of their members in the area of worker health and safe-

ty as well as environmental and neighbourhood protection.

• For them, an environmental management system safeguards these interests if basic substantive le-

gal requirements and environmental and health protection standards are laid down as requirements

upon the management system and are verified in order to achieve improvements going beyond min-

imum statutory requirements.

• Environmental management systems according to ISO 14001 must not be used to undermine more

demanding, effective and legally binding instruments and standards.

• ISO 14001 contains weak points: During certification, compliance with national environmental reg-

ulations is not verified, the organizational focus makes it possible that only parts of sites are certi-

fied and problematic sites excluded, and there is a lack of orientation to performance standards or

technology standards (e.g. best available technology). As a result, arbitrary improvements, even such

below the minimum legally permitted level, do not stand in the way of certification.

• Provisions regarding the participation of staff are insufficient in ISO 14001; clear participation re-

quirements have to be established – this means access to environmental information, sufficient qual-

ification and real opportunities for participation.

• The revision process should be used to establish a high level for ISO 14001: Part of this is the elim-

ination of the weak points mentioned. In addition, the participation of the relevant societal groups in

the standardization and revision process has to be ensured, i. e. next to companies and business as-

sociations, environmental organizations, unions, consumer organizations and representatives of sci-

ence have to be involved in a binding way and with equal rights (on a worldwide scale if possible).

• An advantage of ISO 14001 is that – if applied worldwide – it establishes the organizational frame-

work for the improvement of environmental protection and that it is part of a series (‘tool box’) which

can help bring about actual improvements. ISO 14001 applied on its own and minimally is not suf-

ficient.

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Comments made by the environmental organizations

• Exemplary corporate environmental action is expressed in a consistent, credible integration of envi-

ronmental protection into corporate strategy as well as in concrete, environmentally sound outcomes,

products, services and concepts.

• Against that background, an environmental management system according to ISO 14001 can only

be a very first step.

• In addition, the environmental management system according to ISO 14001 is not designed for

communication and external effect.

• The European environmental management system (EMAS) appeals more to the public and environ-

mental associations. It goes beyond ISO 14001 regarding performance requirements and external ori-

entation and is thus a model for the further development of ISO 14001.

• ISO 14001 is only a management system: No concrete minimum standards are demanded (environ-

mental performance, state of the art technology). In addition, it does not ensure compliance with en-

vironmental law. Nevertheless, it does integrate environmental aspects and environmental instru-

ments into business on a daily basis.

• The weakest point is the lack of an external effect: There is no (normally matter-of-course) obligation

to give account of the use of natural resources and to support environmentally friendly principles via

a verified environmental statement.

• The achievement orientation, the assurance of compliance with relevant environmental regulation,

the participation of staff as well as the external communication and provision of environmental in-

formation should all be strengthened. Furthermore, product-oriented environmental management

should be intensified.

• In the process, a stronger, equal representation of environmental organizations – especially on an in-

ternational level – is to be supported.

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Comments made by the associations of Germany industry

• For the chambers of commerce, environmental management and environmental management systems

are very important issues because we are interested in making the achievements of commerce and

industry for environmental protection transparent.

• The DIHT (Deutscher Industrie- und Handelskammertag), the Association of German Chambers of In-

dustry and Commerce, supports companies in setting up ISO 14001 and/or EMAS although the sys-

tem as such says nothing about the results achieved: Important benefits of an EMS can be realized

through EMAS as well as through ISO 14001.

• The DIHT thinks that ISO 14001 as a world standard is important for the dialogue on corporate en-

vironmental protection. The standard creates a platform for the continual improvement of corporate

environmental protection. The exchange of experience, best practice etc. is easier when the basis –

the management system – is the same.

• The strongest point of ISO 14001 is the proximity in its procedures to the quality management sys-

tems and also the comparatively large openness of the system for individual implementation. Final-

ly, the worldwide validity and thus the meaning of the certificate is very important for users.

• For the medium-sized companies, the comparatively high ‘paper burden’ of the system is its greatest

disadvantage – also compared to EMAS I.

• The DIHT would wish the ISO 14001 standard to be stable for a lengthier period in order to evalu-

ate the experience from two or three auditing cycles, perhaps in five years time. In the medium-term,

though, the question will arise whether specific system standards will still be justified or whether the

future belongs to an integrated management system.

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III.4.4 Findings of other surveys and international experience

Results of the survey concerning ISO 14001 revision, conducted by the

Federal Association of German Industry (Bundesverband der Deutschen In-

dustrie, BDI) and the Association of German Chambers of Industry and

Commerce (DIHT)

In preparation for the upcoming revision of ISO 14001:1996, the BDI and the DIHK, in cooperation

with the German Association of Chemical Industries (Verband der Chemischen Industrie, VCI),

launched in late 1999/early 2000 a survey among the users of the standard in German industry. This

concentrated essentially on the issues that had emerged in the revision process within ISO TC 207

SC1 at that point in time. Some 400 companies participated in the survey.

Issues and findings of the survey

Compatibility of ISO 14001 with ISO 9001?

The responses of German industry confirmed the work undertaken at the ISO level. The companies

strongly support an improved alignment of the ISO environmental and quality management system

standards, in order to enhance compatibility between the environmental management standard and the

ISO 9000ff series. This does not imply a call for integration by merging the two to create one man-

agement system standard.

Legal compliance: Is there a need for amendment?

Companies in Germany have an open attitude to the issue of legal compliance. They are willing to fur-

nish proof that their operations comply with the law, and are in favour of concretizing ISO 14001:1996

in accordance with EMAS provisions. Indeterminate and negative responses do not mean that these

companies do not aim to comply with environmental law. They rather do not expect ‘improved’ stan-

dards to yield improved compliance, and therefore do not anticipate any value added by the work of

ISO TC 207 SC1.

Initial environmental review: The European EMAS scheme already provides for an initial environmen-

tal review as the first step towards setting up an environmental management system. Most (50%) of

the companies surveyed are in favour of introducing this system element in ISO 14001, too.

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77


External communication (reporting) as a ‘new’ element of ISO 14001?

This issue is already contained today in ISO 14001:1996. The growing interest at ISO level in ad-

dressing environmental reporting prompted the German industry associations to include this issue in

the survey. A majority (167) of the companies reject a modification of ISO 14001:1996. However, a

considerable number (142) view such modification positively. The industry associations interpret this

as a reflection of different company sizes. On the one hand, environmental reporting is established

practice in many companies; on the other hand, sobering experience has already been made with stan-

dardized reporting pursuant to EMAS (lack of interest among the public).

Focus ISO 14001 more strongly on product design for the environment (DfE)?

In the industry responses, approval slightly exceeds rejection (158:147). Particularly considering the

current European debate on IPP (integrated product policy), deliberations on developing environmen-

tal management system standards in this direction come as no surprise to the industry associations.

This issue was already deliberated in detail in Europe during the EMAS revision process (from 1997

to 2001), and has been included in EMAS II.

Integrating the ISO 14031 (environmental performance evaluation) guideline?

A large majority of German industry (65%) rejects integration of the ISO 14031 guideline. The com-

panies do not call into question the issue of environmental performance evaluation as such, but doubt

whether its standardization within ISO 14001 can bring the issue forward – after all, this was debat-

ed at length in the course of work on ISO 14031.

German Federal Environmental Agency (Umweltbundesamt, ed.):

Betrieblicher Umweltschutz mit System – EG-Umweltaudit in Deutschland.

Erfahrungsbericht 1995 bis 1998 (Systematic corporate environmental pro-

tection – EC eco-auditing in Germany: Experience from 1995 to 1998),

Berlin 1999

This report is based on a survey of all EMAS-registered German sites until the end of 1998 (1806 par-

ticipants, return rate 70%, 1228 questionnaires analysed). Amongst others, the following issues were

examined: Reasons for participation, cost-benefit ratio of participation, environmental statement, ex-

perience with the environmental verifier, further support, wishes regarding improvement, relationship

between EMAS and ISO 14001.

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78


Partly, there is a strong correspondence between the results of this report and those of the present sur-

vey. This does not come as a surprise since a considerable proportion of EMAS companies is also cer-

tified to ISO 14001. For the participating EMAS companies, worldwide validity, positive effects of

combining the two systems, good compatibility with ISO 9001 and greater practicability and user

friendliness are points that determined the decision to opt for additional ISO 14001 certification. De-

cisions not to opt for additional ISO 14001 certification are explained by the duplication of effort that

this would involve, and various pro-EMAS arguments such as greater public-relations impact or

stronger focus on performance.

Dyllick, Thomas; Hamschmidt, Jost: Wirksamkeit und Leistung von Umwelt-

managementsystemen: eine Untersuchung von ISO 14001-zertifizierten Un-

ternehmen in der Schweiz (Effectiveness and performance of environmen-

tal management systems: A survey of ISO 14001 certified companies in

Switzerland); Zurich: vdf, 2000

This Swiss survey focuses on the reasons for as well as environmental and economic effects of the im-

plementation of environmental management systems. For this, a written survey of ISO 14001 certified

organizations in Switzerland was conducted in 1999 and 158 questionnaires analysed.

One result of this study is the uncovering of a “strategic deficit” of the ISO 14001 standard. This is

an important result within the revision context, since it concerns the debate on the terminology, de-

limitation and purposefulness of the standard requirement 4.3.3 “Objectives and targets”, which plays

a role in the present survey (see the section on clause-specific lack of clarity) as well as in the stan-

dardization committees’ discussions. Combining these terms and requirements would certainly not

serve to strengthen the strategic management level, nor would it serve clarity and systematic structure.

Indeed, a stronger emphasis on the strategic environmentally oriented setting of targets and their in-

tegration into general corporate strategy could help remedy both the strategic deficit and the lack of

clarity regarding terminology.

Wehrmeyer, Walter (ed.): ISO 14001 – Case Studies and Practical Experi-

ences, Greener Management International – The Journal of Corporate Envi-

ronmental Strategy and Practice, Issue 28, Sheffield, 1999

The case studies presented highlight the breadth of possible applications: from group certification of

30 SMEs to the global certification of a globally operating bank. One contribution emphasizes the com-

paratively greater stringency, performance and communication focus of EMAS. Other studies deal with

the inclusion of environmentally oriented product development and of suppliers and other interested

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79


groups, with the application of environmental indicator systems (ISO 14031), the requirement of bet-

ter provision of environmental information and the perspectives of environmental management systems

within the context of sustainable development.

The characterization of ISO 14001 by the editor as the “Model T among the environmental manage-

ment systems: not the most progressive but affordable” is confirmed by the case studies. One of the

main problems for users is the fact that with the intended general applicability shown impressively in

the case studies, the concrete character of ISO 14001 as a tool and guideline must remain limited.

This is confirmed by the results of the present survey, in which the participants call for more support,

e.g. through further information and examples in the annex of the standard.

PhD Students’ Network on Environmental Auditing (Doktoranden-Netzwerk

Öko-Audit e.V., ed.): Umweltmanagementsysteme zwischen Anspruch und

Wirklichkeit – eine interdisziplinäre Auseinandersetzung mit der EG-Öko-Audit-

Verordnung und der DIN EN ISO 14001 (Environmental management sys-

tems between demands and reality – an interdisciplinary discussion of the

EMAS Regulation and ISO 14001), Berlin, Heidelberg: Springer-Verlag, 1998

Various authors in this collection of articles focussing on eco-auditing deal with ISO 14001: Peter M.

Thimme gives a comparative overview of the development of EMAS and ISO 14001 as well as their

goals and requirements; Gabriele Poltermann presents the results of an empirical study of 75 ISO

14001 certified companies (return out of 164 questionnaires sent out).

Thimme elaborates on the differences between EMAS and ISO 14001. According to him, the aim of

ISO 14001 is to provide a formal framework for environmental management systems, and one advan-

tage of it is the comparatively clearer structure of the standard, one disadvantage the lack of environ-

mental reporting. Poltermann, in her empirical study conducted in 1997, arrives at results largely sim-

ilar to those of the present survey. She finds that the overall evaluation of ISO 14001 by its users is

positive, but slightly poorer than that of EMAS, which can be put down mainly to the poorer credibil-

ity of ISO 14001.

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80


Steger, Ulrich et al.: Umweltmanagement in der Praxis – Teilergebnisse eines

Forschungsvorhabens (Teile I bis III, V und VI) zur Vorbereitung der 1998

vorgesehenen Überprüfung des gemeinschaftlichen Öko-Audit-Systems (En-

vironmental management in practice – parts of the results of a research

project (Parts I – III, V and VI) for the preparation of the review of the Com-

munity eco-audit system envisaged for 1998), ed.: German Federal Environ-

mental Agency (Umweltbundesamt), Berlin 1998

In order to provide support to German environmental policy in the review of EMAS envisaged for 1998,

a research group was commissioned by the Federal Environment Ministry and the Federal Environ-

mental Agency to evaluate experience made with EMAS. EMAS experience was examined from six per-

spectives (“spotlights”): literature review, pilot projects, environmental statements, legal analysis, par-

ticipating companies, other parties.

The majority of the findings concern EMAS or environmental management systems in general. ISO

14001 is mentioned in the literature or literature review and in the context of the future of EMAS. The

additional or higher requirements of EMAS are picked out as a central theme but also the user friend-

liness of ISO 14001, its “clearer structure” and “more comprehensible language”. As a disadvantage

of ISO 14001 the (potential) “bureaucratic burden” is mentioned. The recommendations emphasize

the necessity and purposefulness of positioning the two systems in a differentiated manner: EMAS as

the more demanding system compared to ISO 14001, with an “ecological star performance”.

Schwarz, E.J., Vorbach, S., Grieshuber, E.: Analyse des Nutzens unter-

schiedlicher Umweltmanagementsysteme (Analysis of the benefit of differ-

ent environmental management systems), ed.: Austrian Ministry of the Envi-

ronment, Youth and Family, Klagenfurt, 1999

Commissioned by the Austrian Environment Ministry, the University of Klagenfurt conducted 204 ex-

pert interviews with CEOs or environmental managers of 133 Austrian companies with environmental

management systems, as well as a literature review.

The study finds that, compared to Austrian EMAS sites, ISO 14001 companies place more emphasis

on cost-benefit arguments. According to the findings, the EMAS-specific requirement of an environ-

mental statement drives one third of the companies interested in setting up an environmental man-

agement system into the arms of ISO 14001. For ISO 14001 certified companies, the impulse to set

up the system came mostly from clients/customers or suppliers, which are also the targets of their com-

munication efforts. That ISO 14001 companies receive more (positive) responses from their customers

than EMAS companies is put down to this circumstance. Regarding the further development of both

environmental management systems, a differentiation strategy is preferred that highlights the special

strengths of EMAS.

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A number of further case studies, surveys and reports from all over the world give an impression of the

international range and importance of ISO 14001:

Further case studies and reports (a selection)

International Network for Environmental Management e.V.:Perspectives on ISO 14001 & SMEs from Australia, Hungary, Ireland, Slovakia and Thailand, Hamburg 1999

Industrial Development Bureau, Ministry of Economic Affairs:ISO 14001 in Taiwan, Taipei, March 2000

National Standardization Agency of Indonesia (BSN):Standardization, Industry and ISO 14001, Jakarta, June 2000

The World Bank’s official report for the Guadalajara (Mexico):Environmental Management Pilot; prepared for Mexico’s environmental agency (SEMARNAP)

Zackrisson, M., Enroth, M.:Environmental Management Systems – Paper Tiger or Powerful Tool; Swedish Institute of Production Engineering Re-search IVF, April 2000

Hillary, R.:Small and Medium-sized Enterprises and ISO 14001: What are the Implications, London, May 1998

Morrison, J. et al.:Managing a Better Environment: Opportunities and Obstacles for ISO 14001 in Public Policy and Commerce, PacificInstitute for Studies in Development, Environment and Security, USA, Oakland, March 2000

Engel, H.:EMAS and ISO 14001 in Belgium, Brussels 1999

Edwards, B. et al.:The Effectiveness of ISO 14001 in the United States, University of California, April 1999

Tejera, J.:Report on the Implementation of ISO 14001 and the Use of ISO 14004 by SME’s, AENOR, Madrid, April 1998

OECD Group on Pollution Prevention and Control:Review of the Development of International Environmental Management Systems – ISO 14000 Standard Series, Paris,May 1998.

Multi-State Working Group (MSWG) on Environmental Management Systems:Statement of Considerations for the Review and Revision of 14001, Raleigh, NC, USA, September 1998

California Environmental Protection Agency:ISO 14001 Environmental Management System (EMS) Pilot Study, January 1998

ISO 14001 Workshop, San Francisco, June 1998:Stans, J.: Experiences with certification under ISO 14001 in the Netherlands; Nakamaru, S.: Implementation of ISO14001: Japanese experience and expectations; Labbé, E.: Experiences on ISO 14001 – Implementation and Certifi-cation in Argentina; Andersen, T.: Implementation of ISO 14001 in Denmark; Soutter, D.: ISO 14001 implementationissues in South Africa; McKiel, M.: ISO 14001 and EMS implementation in the USA; Larsson, K.: Using ISO 14001together with EPE, LCA and Environmental Product Declaration in Sweden; Guan, P.: ISO 14001 implementation inSingapore; Carvalho, A.: ISO 14001 – Implementation in Brasil; Prando, R.: Recent advances on implementation ofISO 14001 in Uruguay; Lister, N.: UK experience in the implementation of ISO 14001, ISO 14001 Workshop, SanFrancisco, June 1998

Corbett, C.J./Kirsch D.A.:The Linkage between ISO 9001 and ISO 14001 Standards: An International Study, Ciber Working Paper Series, TheAnderson School at UCLA, Los Angeles, 1999; ISO 14001: An Agnostic’s Report from the Frontline, April 2000; In-ternational Diffusion of ISO 14000 Certification, January 2000.

United States-Asia Environmental Partnership:Global Environmental Management – Candid Views of Fortune 500 Companies, 1997

Terui, K.:Implementation of ISO 14001 and Japan’s Perspectives, MITI, 1998

Japanese National Committee for ISO/TC 207/SC1/SME:Implementation of ISO 14001 in Japanese SMEs, 1998

Nakamaru, S:Establishment of EMS in Japanese SMEs, May ‘99; Implementation of ISO 14001 – the Japanese Experience, June ‘99

Page

82

IV. Conclusions


Page

83

IV.1

Considerations and recommendations for a German position

53 The specifications for the revision process formulated by the responsible committee ISO TC 207, and the question of how to interpret them, have thereforeled to major discussions in the working group responsible for the process – to some, the specifications seem too restrictive.

IV.1.1

General considerations

Formulating a position regarding

the individual issues of ISO

14001 revision is unproblematic

when it comes to efforts to en-

sure greater clarity and compati-

bility without changing the level

of the standard: All of the partic-

ipants in the revision process

strive for these goals.

The borderline, though, between

changes that serve clarification

or compatibility with ISO 9000ff

and “additional requirements”,

which are not to be considered

in the current revision process

but only recorded, is fluid. The

final decision on what is to be

regarded as clarification, com-

patibility or additional require-

ment will be taken by the rele-

vant standardization commit-

tees.53

The suggestions, wishes and

comments made by participants

in the present survey, however,

make it very clear that “lack of

clarity” refers not only to lack of

clarity in the text or wording but

also to a large extent to content-

and methodology-related ques-

tions and uncertainties. For in-

stance, regarding the “Environ-

mental aspects” part of ISO

14001, the issue is not essen-

tially what this term means, it is

how the user can and should

identify those environmental as-

pects that have a significant en-

vironmental impact. The inde-

terminate term “significant en-

vironmental impact” creates un-

certainty among users. After all,

this is a pivotal issue for envi-

ronmental management, be-

cause these environmental as-

pects have to be taken into con-

sideration when setting environ-

mental targets, developing the

environmental programme, in

organizational structures and

staff qualification etc.

So if the ISO 14001 revision

process is thus also – at least la-

tently – about questions of con-

tent and requirements, then

from a German and European

perspective the basic question

of desired contents or require-

ments arises and, with this, the

desired relation between ISO

14001 and EMAS with their dif-

fering requirements. This was

elaborated in some of the stud-

ies mentioned and identified by

some of the participants in the

present survey. Three different

(opposed) strategic approaches

were suggested:

Strategy 1:

Not to increase the quality of

ISO 14001 too much, in order

to retain the differences to

EMAS and prevent EMAS from

becoming superfluous.

Strategy 2:

To extensively align and bring up

ISO 14001 requirements to

those of EMAS in order to make

EMAS superfluous.

Strategy 3:

To render ISO 14001 upwards-

compatible with EMAS, in order

to make it possible to apply ISO

14001 in a first step and then,

building upon this, implement

EMAS.

ISO 14001 is the most important


tem worldwide. EMAS, though,

has (in Europe) the potential to

deliver added value – due to its

specific additional requirements

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84

IV.1Considerations andrecommendations for aGerman position

(legal compliance, performance,

communication/environmental

statement, staff participation,

registration) and due to its legal

establishment as an EU Regula-

tion.

If the basic environmental policy

decision in Europe and Germany

in favour of keeping EMAS, i.e.

keeping two systems, is to be

upheld (and there are good rea-

sons for doing so), a differentia-

tion strategy must follow be-

cause, in the long run, two equal

and similar systems would have

no chance or right to exist in

parallel. EMAS, as a ‘higher po-

sitioned stamp of quality’, must

always provide (even if ISO

14001 is enhanced in terms of

quality) a sufficiently higher ca-

pability and more binding nature

– and at the same time a corre-

sponding benefit for users – if it

is not to become obsolete.

Of course, it would be false to

conclude that the level of ISO

14001 should be lowered or not

raised, to the detriment of envi-

ronmental protection and the

more progressive economies, in

order to ‘save’ EMAS. On the

contrary: Integrating major ele-

ments “of EMAS into a more de-

manding ISO 14001 (ISO

14001plus)” would “not only

support the worldwide introduc-

tion of environmental manage-

ment systems but would speed

it up”.54 The recommended

strategy would thus be: Further

development of ISO 14001

without making EMAS obsolete.

Therefore, the European task is

to guarantee the added value of

EMAS in the shape of more de-

manding requirements upon and

additional benefits for users.

Further development of ISO

14001 does not automatically

mean that too much is expected

of less capable companies and

societies. The prominent calls

for legal compliance (oriented

towards national environmental

requirements), best available

technology (oriented towards

economic feasibility) or commu-

nication (oriented towards exist-

ing and suitable communication

methods) are always relative and

show that ‘additional require-

ments’ do not mean ‘additional

burdens’, especially since ‘addi-

tional benefit’ can follow, to

varying degrees, for the organi-

zations using these elements.

54 Rat von Sachverständigen für Umweltfragen (SRU, German Council of Environmental Advisors): Umweltgutachten 2000. Schritte ins nächste Jahrtausend(Kurzfassung Teil I), Nr. 36, p.15, Stuttgart 2000.

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85


IV.1.2 Concrete

recommendations

The conditions of the current re-

vision do not permit any funda-

mental changes to ISO 14001.

This is welcomed by those who

wish ‘standard stability’. On the

other hand, some call for funda-

mental changes, e.g. a rigorous

alignment with the process ori-

entation of ISO 9001:2000.

These changes cannot be ad-

dressed within the current revi-

sion process. Other suggestions,

e.g. listing all relevant environ-

mental laws and regulations in

the annex of ISO 14001, refer

to specific national circum-

stances and thus cannot be in-

tegrated into an international

standard. These are therefore

not included in the following list

of recommendations. Apart from

this pre-selection, all sugges-

tions made by respondents to

the survey are included in the

following list of recommenda-

tions. No decisions were taken

on whether they are to be classi-

fied as clarification only, or

rather as modifications to re-

quirements.

Aspect

Definitions in general

Comment

For the users, the improvement

of terminological clarity, com-

prehensibility and consistency

within the standard and between

the standards of the ISO 14001

series and ISO 9001:2000 (as

well as EMAS) is a major issue.

General review and standardiza-

tion of the terminology; linguis-

tic revision of the definitions

and their German translation;

matching of differing definitions

(environmental performance in

ISO 14001 and ISO 14031);

explanation of the meaning (in

the German translation) of the

words “shall”, “shall not”,

“should” and “should not”.

Figure 43

RecommendationsRecommendations

Page

86


Environmental aspects There is a lack of clarity in ap-

plication especially regarding

the question of what “signifi-

cant environmental impacts”

are and how the respective envi-

ronmental aspects can be iden-

tified.

Revision and more concrete

terms of the requirements as

well as the explanations in an-

nex A (taking into consideration

the results of the ISO 14004

discussion and referring to

these); clarification of the mean-

ing (in the German translation) of

“aspects”, “impacts” and “sig-

nificance”.

Aspect

Environmental policy

Comment

A large part of the German ISO

14001 certified companies sup-

ports placing emphasis on per-

formance and legal compliance,

moving away from pure system

orientation; for most of the Ger-

man ISO 14001 companies this

would merely confirm their nor-

mal practice.

In the requirements regarding

environmental policy, it should

be made clear that the manage-

ment system must be oriented

not only towards itself, but to-

wards achieving and assuring re-

sults in terms of legal compli-

ance and environmental per-

formance with regard to all sig-

nificant environmental aspects;

clarification of the meaning (in

the German translation) of “com-

mitment to compliance”, “con-

tinual improvement”, “preven-

tion of pollution” and “aspects”.

Legal and other

requirements

When auditing German compa-

nies, certifiers often find non-

conformance; this is also an

outcome of the complexity of

German environmental law and

its indeterminate boundaries

(e.g. to occupational health and

safety); users want more support

for compliance with this re-

quirement.

Clarification and more concrete

terms for the specifications re-

garding legal requirements and

compliance, and alignment of

these with the specifications re-

garding environmental policy,

monitoring and measurement

and auditing.

Recommendations

Page

87


55 “Sustained integration of environmental protection into daily corporate routines succeeds all the better if the environmental management system is support-ed jointly by management, staff and, where appropriate, staff representatives.” Cited from: National foreword to the German version DIN EN ISO14001:1996.

Aspect

Objectives and targets

Comment

The terms and their delimitation

as well as their relation to the

environmental policy and “envi-

ronmental programmes” is not

clear to many users; the strate-

gic component tends to be neg-

lected.

Clarification of the requirement,

greater differentiation of terms

and emphasis on the strategic

component of environmental ob-

jectives.

Organizational structure

and responsibility

German users are occasionally

uncertain whether the manage-

ment representative of top man-

agement has to be from top

management as well.

Clearer wording.

Training, awareness and

competence

German certifiers relatively of-

ten find nonconformance to this

requirement; staff participation

is seen as a core issue by all

participants.55

The meaning of this requirement

for the effectiveness of an envi-

ronmental management system

should be made clearer; intro-

duce more far-reaching specifica-

tions on staff participation – cf.

“additional requirements”.

Communication Environmental protection is an

issue of social needs and not

only has to do with organizations

and their customers; environ-

mental reporting is in some in-

stances normal practice.

Pro-active external information

and communication about objec-

tives and performance should be

more strongly grounded in ISO

14001 – cf. also “additional re-

quirements”.

Recommendations

Page

88


Aspect

Environmental manage-

ment system documen-

tation, document con-

trol and records

Operational control

Emergency prepared-

ness and response

Checking and correc-

tive action

Comment

The requirements for documen-

tation are often seen as unnec-

essary and very costly; business

practice is burdened on one

hand by standard-independent

requirements for documentation

and on the other hand by the (by

now obsolete) document orien-

tation of quality management.

The German users and certifiers

judge the wording of this central

requirement to be inadequate;

this is aggravated through the

lack of explanation in the annex

of ISO 14001:1996.

This requirement is partly

judged as not sufficiently ex-

plained; explanation in the an-

nex is missing; in addition, a

certain need for alignment with

ISO 9001 is seen.

Occasionally, problems of de-

marcation to and a need for

matching with ISO 9001:2000

are perceived.

Clarification and more precise

definition of “records”, “docu-

ments” and “documentation” in

coordination with the require-

ments of the quality manage-

ment standard ISO 9001:2000;

make clearer when, whether and

which process due to be esta-

blished should be a documen-

ted process.

In a manner commensurate with

its significance in terms of both

substance and presentation, for-

mulate more precisely and explain

in the annex, taking into conside-

ration the results of the discussion

on ISO 14004; include reference

to other relevant standards in the

ISO 14000 series (e.g. on pro-

duct development).

Formulate more precisely and ex-

plain in the annex, taking into

consideration the results of the

ISO 14004 discussion; pay atten-

tion to alignment with ISO

9001:2000 (“nonconformity

control” and “preventive action”).

Pay attention to matching with

ISO 9001:2000 (“control”,

“nonconformity control” and

“corrective action”).

Recommendations

Page

89


Aspect

Environmental manage-

ment system audit,

management review

Annex

Comment

There are questions regarding

the evaluation and demarcation

of internal audit and manage-

ment review; a major part of the

German ISO 14001 certified

companies supports an empha-

sis on performance and legal

compliance (moving away from

pure system orientation); for

most of the German ISO 14001

certified companies, this would

merely confirm their common

practice; some respondents

miss more concrete specifica-

tions and information on con-

ducting audits and the neces-

sary qualification of internal au-

ditors.

The users often feel left alone

with the pure, abstract require-

ments of the standard; they

make diverse suggestions for ex-

panding the annex, especially

with explanations, examples, in-

dustry-specific interpretations,

register of relevant regulation,

notes on the integration of differ-

ent management systems.

Explain demarcation between in-

ternal audit and management re-

view in the annex; make clear in

the requirements (and title) that

the audit is not only oriented to

the management system but also

to the question of whether the de-

sired results have been achieved.

Provide references to methods of

environmental performance eval-

uation (ISO 14031); explain the

connection to ISO 14040ff (or

ISO 19011) and clarify to what

extent the qualifications of inter-

nal auditors must match those of

external auditors; align with the

requirements and definitions of

the quality management system

(ISO 9001:2000).

Use the annex to improve the

‘tightrope walk’ between general-

ly valid requirements and concre-

te reference; for this, make more

concrete the purposes, positions

of and relationships among the

‘specification laying down requi-

rements’, the ‘explanatory annex

as guidance on use’ and ‘further

guidelines (ISO 14004)’; revise

annex A and add explanations of

“operational control”, “emergen-

cy preparedness and response”

and “monitoring and measure-

ment”.

Recommendations

Page

90


Aspect

Additional requirements

Certification

Comment

One advantage of ISO 14001 is

the fact that it is part of a whole

series of standards; extensive

requirements such as those con-

cerning the use of environmen-

tal indicator systems (ISO

14031), external communica-

tion (standardization activities

regarding reporting), integration

of products (product develop-

ment: ISO/TR 14062, environ-

mental labels and life cycle as-

sessment: ISO 14020 series

and ISO 14040 series) there-

fore do not have to be treated

within ISO 14001; an environ-

mental management system ac-

cording to ISO 14001, though,

should have a certain level of

completeness, operability and

credibility; requirements only

then exert binding effect and

come into widespread use if

they are established within ISO

14001 itself.

Mostly for cost reasons, the users

partly want to extend the certifi-

cation cycle56; some call for a

“confidence audit” or “more con-

sulting than monitoring”; the cost

of certification must yield a ben-

efit that stems from the inde-

pendence and credibility of the

certification.

In ISO 14001, the (existing) mi-

nimum standards e.g. regarding

external communication should

be elaborated upon and phrased

in such a way that they lead to

an acceptable, sustainable level

if applied by themselves; they

should moreover provide the ba-

sis or interface for the applica-

tion of ISO 14031, the ISO

14020 series and the ISO

14040 series; the ‘tool box’ of

the ISO 14000 series should be

expanded to include support re-

garding reporting/external com-

munication and environmental

cost management. Specifica-

tions regarding the integration

of staff as a core success factor

and requirement of the manage-

ment system should be intro-

duced into ISO 14001.

Ensure the independence, com-

petence and qualification of ex-

ternal environmental manage-

ment system certification audi-

tors; the future text of ISO

19011 should not fall short of

ISO 14010ff.

Recommendations

Page

91


56 In EMAS, the opposite path was taken and annual reviews introduced (with exemptions for smallcompanies).

Aspect

Information and public

relations work

Comment

Without external advice, many

organizations are unable to set

up an environmental manage-

ment system according to ISO

14001; for the users, questions

arise again and again that re-

main unresolved; consultants

and certifiers are not authorized

to interpret the standard.

More information on the ISO

14000 series; establishment of

an authorized help desk, which

supplies answers to frequently

asked questions, aids for inter-

pretation etc. or brings about

clarification by the standardiza-

tion committees; establishment

of a database of certified organi-

zations.

The problems emphasized by the survey participants are already

topics of debate within the current revision process. However, sub-

stantive debate takes place mostly within the context of ISO 14004

revision. Therefore attention and effort needs to be focussed on en-

suring that the outcomes of this debate express themselves as im-

provements within ISO 14001, too. For it is this standard that is

relevant to companies as a specification and basis for certification.

Recommendations

Page

92

V. Lists and imprint


“… we wish a free-of-charge hotline or helpdesk.”

Page

93

V.1 Lists

V.1.1 References

Bundesverband der Deutschen Industrie/Deutscher Industrie- und Handelstag:Ergebnisse der Umfrage zur Revision von ISO 14001, Unterlage des DIN – NAGUS, 7/2000

(Federal Association of German Industry/Association of German Chambers of Industry and Commerce:

Results of the survey concerning ISO 14001 revision; on file at DIN-NAGUS, 7/2000)

Doktoranden-Netzwerk Öko-Audit e.V. (Hrsg.):Umweltmanagementsysteme zwischen Anspruch und Wirklichkeit – eine interdisziplinäre Auseinadersetzung mit der EG-Öko-Audit-Verordnung undder DIN EN ISO 14001, Springer-Verlag, Berlin, Heidelberg 1998

(PhD Students’ Network on Environmental Auditing (Ed.): Environmental management systems be-

tween demands and reality – an interdisciplinary discussion of the EMAS Regulation and ISO 14001)

Dyllick, Thomas;Hamschmidt, Jost: Wirksamkeit und Leistung von Umweltmanagementsystemen: eine Untersuchung von ISO 14001-zertifizierten Unternehmen inder Schweiz; Zürich: vdf, 2000

(Effectiveness and performance of environmental management systems: A survey of ISO 14001 certi-

fied companies in Switzerland)

International Organization for Standardization:

The ISO Survey of ISO 9000 and ISO 14000 Certificates – Ninth cycle: up to and including 31 Decem-

ber 1999, Geneva 2000

Schwarz, E.J., Vorbach, S., Grieshuber, E.:Analyse des Nutzens unterschiedlicher Umweltmanagementsysteme, Hrsg.: Bundesministerium für Umwelt, Jugend und Familie, Klagenfurt, 1999

(Analysis of the benefit of different environmental management systems; published by the Austrian

Ministry of the Environment, Youth and Family)

Steger, Ulrich et.al.:Umweltmanagement in der Praxis – Vorläufige Untersuchungsergebnisse und Handlungsempfehlungen zum Forschungsprojekt sowie Teilergebnisseeines Forschungsvorhabens (Teile I bis III, V und VI) zur Vorbereitung der 1998 vorgesehenen Überprüfung des gemeinschaftlichen Öko-Audit-Sys-tems, Ed.: Umweltbundesamt, Berlin 1998

(Environmental management in practice – results of a research project for the preparation of the re-

view of the Community eco-audit system envisaged for 1998; published by the German Federal Envi-

ronmental Agency)

Umweltbundesamt (Ed.):Betrieblicher Umweltschutz mit System – EG-Umweltaudit in Deutschland – Erfahrungsbericht 1995 bis ‘98, Berlin 1999

(Systematic corporate environmental protection – EC eco-auditing in Germany: Experience from 1995 to

1998; published by the German Federal Environmental Agency)

Wehrmeyer, Walter (Ed.):

ISO 14001 – Case Studies and Practical Experiences, Greener Management International – The Jour-

nal of Corporate Environmental Strategy and Practice, Issue 28, Sheffield 1999

Page

94

V.1Lists

V.1.2 Figures

The ISO 14000ff standard seriesBy category, listing the respective subcommittee (AA) within the responsible German standardization committee (DIN-NAGUS)

The German Standardization Committee for Basic Principles of Environmental Protection (DIN-NAGUS)Subcommittees, responsibilities and international counterparts (Subcommittee SC= Arbeitsausschuss AA)

ISO 14001 revision schedule

Target groups of the survey “ISO 14001 in Germany”

Structure of the survey “ISO 14001 in Germany”

Questionnaire for certified organizationsreduced in size


Guiding questions for the interviews with interested party representatives

Estimated correlation between ISO 14001 certified companies, certificates issued and certified sites in Germany (2000)

Overview of TGA-accredited and DAU-accredited environmental auditorsand relationships between them and the organizations audited

Industrial sectors of the organizations captured by the survey(EAC Code Nos. 1-39)

Industrial sectors of ISO 14001 certified organizations:Worldwide; in Japan; in Germany; covered by the present survey (EAC Code)

Size of the organizations in the surveyby number of staff

Size of the organizations in the surveyby turnover

Proportions of organizations surveyed with turnover generated outside the European Unionand the share of this in company turnover

Certification status of the organizations surveyed in Germany (as of October 2000)

Management system combinations applied by the organizations surveyed and their chosen sequence of introduction

Accreditation status of ISO 14001 certifiers in Germanytaking multiple accreditations into consideration

Combinations of different management systems in certification auditsaccording to certifiers

Reasons for setting up an ISO 14001 environmental management systemfrom the perspective of the organizations surveyed

Main reasons for setting up an ISO 14001 environmental management systemfrom the perspective of the organizations surveyed

BenefitsExpected and actual benefits from setting up an ISO 14001 environmental management system in the organizationssurveyed

Figure 1

Figure 2

Figure 3

Figure 4

Figure 5

Figure 6

Figure 7

Figure 8

Figure 9

Figure 10

Figure 11

Figure 12

Figure 13

Figure 14

Figure 15

Figure 16

Figure 17

Figure 18

Figure 19

Figure 20

Figure 21

Figure 22

Time needed for necessary preliminary work until first ISO 14001 certificationreported by the organizations surveyed

Time needed to set up and maintain an ISO 14001 environmental management systemestimated by the organizations surveyed

Difficulties in setting up and maintaining the ISO 14001 systemViews of organizations and certifers

Proportions of certification audits in which ‘critical nonconformance’ is foundData supplied by certifiers

‘Critical nonconformance’ in ISO 14001 implementation by German organizationsFindings by certifiers in ISO 14001 audits

General comments on problems of clarity in applying ISO 14001 and problems of compatibilitywith ISO 9001Mentions by organizations

Comments on problems of clarity in applying ISO 14001Mentions by organizations

Comments on problems of compatibility with ISO 9001Mentions by organizations and certifiers

Nonconformance, lack of clarity, incompatibility:The criticized clauses of ISO 14001Mentions by certified organizations and certifiers

Support and toolsused or found helpful when implementing ISO 14001 – view of the organizations surveyed

Frequency of unresolved questions concerning ISO 14001 and evaluation of available opportu-nities for clarificationView of organizations surveyed

MeasuresEnvironmental management measures implemented and recommended, and their rating as desirable additional re-quirements of ISO 14001 – from the perspective of certified organizations and certifiers

Legal compliancein practice and its evaluation as an additional ISO 14001 requirement – perspective of certified organizations

Environmental reportingin practice and its evaluation as an additional ISO 14001 requirement – perspective of certified organizations

Evaluation of environmental management principlesfrom the perspective of certified organizations and certifiers

Report for the environmental management systems standard ISO 14001awarded: by 473 German ISO 14001 certified organizations, October 2000

Intention of organizations surveyed to continue certificationWill you continue to seek ISO 14001 re-certification in the foreseeable future?

Further development of number of ISO 14001 certificationsEstimates by certifiers

Opting outProportion of those opting out of ISO 14001 in the future – estimates by certifiers

Wishes and other comments of the organizations surveyed

Concrete Recommendations

Figure 23

Figure 24

Figure 25

Figure 26

Figure 27

Figure 28

Figure 29

Figure 30

Figure 31

Figure 32

Figure 33

Figure 34

Figure 35

Figure 36

Figure 37

Figure 38

Figure 39

Figure 40

Figure 41

Figure 42

Figure 43

Page

95

V.1Lists

Page

96

V.1Lists

V.1.3

Internet addresses

DIN: Deutsches Institut für Normung e.V.(German Institute for Standardization)

ISO: International Organization for Standardization

ISO/TC 207: International Organization for Standardization Technical Committee 207 – Environmental Management

IHK/DIHK: Deutsche Industrie- und Handeslkammer(Association of German Chambers of Industry and Commerce)

Umweltbundesamt, Berlin(German Federal Environmental Agency)

Bundesumweltministerium, Berlin/Bonn(German Environment Ministry)

TGA: Trägergemeinschaft für Akkreditierung GmbH(German Association for Accreditation)

Umweltmanagementnorm ISO 14001This site provides, among other things, all the in-depth analyses on which the present study is based.

Database of ISO 14001 certified companies in England

International ISO 14000 information and discussion center

Statistics of ISO 14001 and EMAS registration worldwide, plus ISO 14000 registered industry analysis of Japan

ECOLOGIA: ECOlogists Linked for Organizing Grassroots Initiatives and Action

International Network for Environmental ManagementThis site contains the ISO 14001 Speedometer, ranking the number of ISO 14001 certificates issued in relation to the population or gross national product of a country.

Thai Industrial Standards InstituteDatabank of ISO 14000 registered organizations in Thailand

www.din.de

www.iso.ch

www.tc207.org

www.ihk.de

www.umweltbundesamt.de

www.bmu.de

www.tga-gmbh.de

www.14001news.de

www.emas.org.uk/iso14001/mainframe.htm

www.iso14000.com/isodiscussions/index.htm

www.ecology.or.jp/isoworld/english/iso14k.htm

www.ecologia.org

www.inem.org

www.tisi.go.th/114000/14000.html

Page

97

V.1Lists

Document

DIN EN ISO 14001

DIN ISO 14004

DIN EN ISO 14010

DIN EN ISO 14011

DIN EN ISO 14012

ISO/DIS 14015

ISO 14020

ISO 14020 DAM 1

E DIN ISO 14021

DIN EN ISO 14024

ISO/TR 14025

DIN EN ISO 14031

ISO/TR 14032

DIN EN ISO 14040

DIN EN ISO 14041

DIN EN ISO 14042

DIN EN ISO 14043

ISO/TR 14049

ISO 14050

ISO 14050 DAM 1

ISO/TR 14061

German title

Umweltmanagementsysteme – Spezi-fikation mit Anleitung zur Anwendung

Umweltmanagementsysteme – Allge-meiner Leitfaden über Grundsätze,Systeme und Hilfsinstrumente

Leitfäden für Umweltaudits – Allge-meine Grundsätze

Leitfäden für Umweltaudits – Au-ditverfahren – Audit von Umweltman-agementsystemen

Leitfäden für Umweltaudits – Quali-fikationskriterien für Umweltauditoren

Umweltmanagement – Umweltbewer-tung von Standorten und Organisatio-nen

Umweltkennzeichnungen und -dekla-rationen – Allgemeine Grundsätze

Umweltkennzeichnungen und -dekla-rationen – allgemeine Grundsätze –Änderung 1

Umweltkennzeichnungen und -dekla-rationen – SelbstdeklarierteUmweltaussagen (Umweltkennzeich-nungen Typ II)

Umweltkennzeichnungen und -dekla-rationen – Umweltbezogene Kennze-ichnung vom Typ I – Grundlagen undVerfahren

Umweltkennzeichnungen und -deklara-tionen – Umweltdeklarationen Typ III

Umweltmanagement – Umweltleis-tungsbewertung - Leitlinien

Umweltmanagement – Beispiele fürUmweltleistungsbewertung

Umweltmanagement – Ökobilanz –Prinzipien und allgemeine An-forderungen

Umweltmanagement – Ökobilanz –Festlegung des Ziels und des Unter-suchungsrahmens sowie Sachbilanz

Umweltmanagement – Ökobilanz –Wirkungsabschätzung

Umweltmanagement – Ökobilanz –Auswertung

Umweltmanagement – Ökobilanz –Anwendungsbeispiele zu ISO 14041zur Festlegung des Untersuchungsrah-mens sowie zur Sachbilanz

Umweltmanagement – Begriffe

Umweltmanagement – BegriffeÄnderung 1

Informationen zur Unterstützung derForstwirtschaft in der Anwendung derISO 14001 und ISO 14004 Umwelt-managementsystem-Normen

English title

Environmental management systems –Specification with guidance for use

Environmental management systems –General guidelines on principles, sys-tems and supporting techniques

Guidelines for environmental auditing– General principles

Guidelines for environmental auditing– Audit procedures – Auditing of envi-ronmental management systems

Guidelines for environmental auditing– Qualification criteria for environ-mental auditors

Environmental assessments of sitesand organizations

Environmental labels and declaration– Basic principles

Environmental labels and declarations– General principles – Amendment 1

Environmental labels and declarations– Self declared environmental claims(Type II environmental labelling)

Environmental labels and declarations– Type I Environmental labelling –Principles and procedures

Environmental labels and declarations– Type III environmental declarations

Environmental management - Envi-ronmental performance evaluation -Guidelines

Environmental management systems –Examples of environmental perfor-mance evaluation (EPE)

Environmental management – Life cycleassessment – Principles and frame-work

Environmental management – Life cy-cle assessment – Goal and scope defi-nition and life cycle inventory analysis

Environmental management – Life cycleassessment – Life cycle impact as-sessment

Environmental management – Life cycleassessment – Life cycle interpretation

Environmental management – Life cycleassessment – Examples of applicationof ISO 14041 to goal and scope defi-nition and inventory analysis

Environmental management –Vocabulary

Environmental management –VocabularyAmendment 1

Informative reference material to assistforestry organizations in the use of ISO14001 and ISO 14004 EnvironmentalManagement System Standards

V.1.4 The ISO 14000ff series

Excerpt from list of DIN-NAGUS publications (as per 29 January 2001)

Currently undergoing revision

Currently undergoing revision

Will be replaced by ISO 19011



2nd edition – German draft standard to be published in April 2001

Draft amendment

NEW!

Draft amendment

Page

98

ISO/Technical Committee 207

„Our vision is the worldwide acceptance and use of the

ISO 14000 series of standards which will provide an ef-

fective means to improve the environmental performance

of organizations and their products, facilitate world trade

and ultimately contribute to sustainable development.“

Published by:

Study prepared by:

Translated by:

Layout by:

Page

99

Bundesumweltministerium (BMU,

German Environment Ministry)

Alexanderplatz 6

D-10178 Berlin

Tel.: +49-1888-305-0

Fax: +49-1888-305-2299

Internet: http://www.bmu.de

Umweltbundesamt (UBA, German

Federal Environmental Agency)

Bismarckplatz 1

D-14193 Berlin

Tel.: +49-30-8903-0

Fax: +49-30-8903-2285

Internet: http://www.umweltbundesamt.de

Dr. Ludwig Glatzner

Büro für Umwelt, Qualität und Sicherheit

Büchnerstraße 16

D-48147 Münster

Tel./Fax.: +49-251-20 19 16

Internet: http://www.14001news.de

Christopher Hay

Übersetzungsbüro für Umweltwissenschaften

Tel.: +49-6151-9535-20, Fax: -21

[email protected]

The views and opinions expressed in this publica-

tion do not necessarily reflect those of the pub-

lishers.

November 2001

1st edition

Commissioned and supervised by:

Peter Franz (BMU – G I 2)

Annette Schmidt-Räntsch (BMU – G I 2)

Reinhard Peglau (UBA – I 2.2)

Dr. Andreas Burger (UBA – I 2.2)

3f design

Sibylle Schmidtchen, Brita Schneider

Rheinstraße 99

D-64295 Darmstadt

Tel.: +49 (0)6151 82786 0

Fax: +49 (0)6151 82786 10

Internet: http://www.3fdesign.de

V.1.4 Imprint

We owe a debt of

gratitude to the

many companies and

organizations that will-

ingly shared their ex-

pertise in the prepara-

tion of this study.

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